CLA-2:49:OT:RR:NC:4:434

Dan Bailey
OnePromo Inc.
675 17th Street Crescent
Hanover, Ontario N4N 3S7
Canada

RE: The tariff classification of lanyards, printed pennants, and flags from China

Dear Mr. Bailey:

In your letter, dated May 5, 2025, you requested a tariff classification ruling. Photos and additional descriptive information were provided for our review.

Item #1, described as a “lanyard,” is designed to be worn around the neck. The lanyard is composed of 100 percent polyester narrow woven, dyed fabric with a dye sublimation printed design. The strap is connected to a lobster claw clasp and measures 16 inches in length by ¾ inch in width.

Item #2, described as a “PVC Pennant Banner” consists of a 25’ length of polyester ribbon with twelve triangular PVC plastic pennants hanging from it at even intervals. On each pennant is printed with a stylized “H” and the team name “Hoosiers.” Per your submission, the printing method is dye sublimation.

Item #3, described as a “flag,” is composed of 100 percent polyester knitted, dyed fabric with a dye sublimation printed design. The fabric is lasered cut and hemmed on all four sides. The rectangular shaped flag measures 60 inches in length by 30 inches in width and features two stainless steel grommets on one vertical end.

The applicable subheading for the lanyard and flag will be 6307.90.9891, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem.

The applicable subheading for the printed PVC plastic pennants will be 4911.99.8000, HTSUS, which provides for “Other printed matter, including printed pictures and photographs: Other: Other: Other: Other.” The column one, general rate of duty will be Free. 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 on the World Wide Web at https://hts.usitc.gov/current.

Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 6307.90.9891, HTSUS, listed above. Merchandise classifiable under subheading 4911.99.8000, HTSUS, constitutes “any information or informational materials” encompassed by 50 U.S.C. § 1702(b)(3). Accordingly, such merchandise is exempt from additional duties under Executive Order 14195 pursuant to heading 9903.01.22, HTSUS.

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. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. For the lanyards and flags, at the time of entry, you must report the Chapter 99 heading applicable to your product classification, 9903.01.25 in addition to subheading 6307.90.9891, HTSUS, listed above. The pennants classifiable in chapter 49, HTSUS, fall within an excepted subheading. At the time of entry, you must report the Chapter 99 headings applicable to your product classification, 9903.01.31 and 9903.01.32, in addition to subheading 4911.99.8000, HTSUS, listed above.

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. Regarding articles the product of China and Hong Kong that are “informational materials,” including goods classifiable in Chapter 49, HTSUS, such merchandise is exempt from additional duties under Executive Order 14257 pursuant to heading 9903.01.31, HTSUS. The reference cards are also exempt by virtue of inclusion in Annex II to Executive Order 14257, under 9903.01.32, HTSUS.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 4911.99.8000 and 6307.90.9891, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, 9903.88.15, in addition to subheading 4911.99.8000 and 6307.90.9891, HTSUS, listed above.

The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.

For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 Regulations (19 CFR 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, contact National Import Specialist Charlene Miller at [email protected].
Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division