CLA-2-39:OT:RR:NC:N5:137
Misuzu Aisaka
Calsak Corporation
970 W. 190th St. Ste 870
Torrance, CA 90502
RE: The tariff classification of a coated polycarbonate sheet from Japan
Dear Ms. Aisaka:
In your letter dated April 1, 2025, you requested a tariff classification ruling.
The product under consideration is Technolloy C101Z which is noted to be an optical sheet. The sheet is
composed of polycarbonate that is coated with polymethyl methacrylate (PMMA). Technolloy C101Z is
imported in dimensions of 1170 millimeters (mm) by 1650 mm x 0.2 mm and can be cut to a customer’s
specifications. The product serves as a light guide panel that allows light to be uniformly distributed. It is
primarily used in a flat panel display; however, it can also be used as a light guide panel for automotive door
sills, backlights for computer keyboards, etc.
You suggest classification of the Technolloy C101Z in 3921.90.4090, Harmonized Tariff Schedule of the
United States (HTSUS). We disagree. Heading 3921 provides for other plates, sheets, film, foil and strip, of
plastics, which are either cellular in nature or are reinforced, laminated, supported or similarly combined with
other materials. The Technolloy C101Z is a noncellular plastic sheet and is not reinforced, laminated,
supported or similarly combined with materials other than plastic. Therefore, Technolloy C101Z is excluded
from classification in 3921.90.4090, HTSUS.
The applicable subheading for the coated polycarbonate sheet will be 3920.61.0000, HTSUS, which provides
for other plates, sheets, film, foil and strip, of plastics, noncellular and not reinforced, laminated, supported or
similarly combined with other materials: of polycarbonates, alkyd resins, polyallyl esters or other polyesters:
of polycarbonates. The rate of duty will be 5.8 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries, including Japan, will be subject to an additional 10 percent ad valorem rate of duty. ?At the time of
entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in
addition to subheading 3920.61.0000, HTSUS, listed above.?
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS
and the accompanying duty rates are provided at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact
National Import Specialist Christina Allen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division