CLA-2-49:OT:RR: NC:5:130
Sayaka Furuyama
The Pack America Corporation
108 West 39th Street
New York, NY 10018
RE: The tariff classification of paper cards with envelopes from Cambodia
Dear Ms. Furuyama:
In your letter, dated June 10, 2025, you requested a tariff classification ruling. A description and photos of
the goods were submitted for our review in lieu of samples.
The items under consideration are a white kraft paper envelope and a white kraft paper card for
correspondence. The card and envelope measure approximately 5.5” wide by 4.3” long. The rectangular
card is printed on its face with the brand name “Veronica Beard”. The card and envelope are for
communicating with customers and associates of the Veronica Beard brand.
The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the
official interpretation of the tariff at the international level. The ENs to Heading 4909, HTSUS, state that the
heading includes “(p)rinted cards bearing personal greetings, messages or announcements for any occasion.
Such printed cards may be illustrated or not and may be with or without envelopes or trimmings.”
Headquarters ruling 966418 defines a message as “any communication, written or oral, sent between
persons.” Ruling 966418 continues that communication may be the conveyance of information. We find that
the printed brand name communicates the brand identity, its reputation, and the source of the
communication. Therefore, we find that the printed cards meet the terms of heading 4909.
The applicable subheading for the white kraft paper envelope and printed paper card will be 4909.00.4000,
HTSUS, which provides for Printed or illustrated postcards; printed cards bearing personal greetings,
messages or announcements, whether or not illustrated, with or without envelopes or trimmings: Other. The
rate of duty will be free.
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,
including Cambodia, 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, 9903.01.25, in
addition to subheading 4909.00.4000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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.
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 Laurel Duvall at
[email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division