CLA-2-97:OT:RR:NC:N433
Kalyan Bhattacharjya
Chromatic Art Private Limited
Villa 184, Geown Oasis, V Kalahalli, Sarjapur Main Road
Bengaluru 562125
India
RE: The tariff classification of an acrylic painting from India.
Dear Ms. Bhattacharjya:
In your letter dated June 25, 2025, you requested a tariff classification ruling. In lieu of samples, an
illustration and description of the painting is provided.
The “Golden Nature” is a framed acrylic painting by artist Parbbonni Bhowmik that is described as an
abstract image of a sunlit forest on a misty morning. The painting is comprised of layers of different shades
of green, white, and black blended with gold leaf. The piece is her work of art created with acrylic paints on
stretched cotton canvas, mounted on a black synthetic plastic resin frame, and the piece bears the date and her
signature on the reverse of the canvas. Furthermore, additional information provided states, (1) the piece took
approximately 15-18 hours to create, (2) the piece is an original and the artist exercised her own aesthetic
imagination and conception in creating the piece, (3) “…the entire surface area of the canvas has been
materially impacted with hand-applied brush strokes, palette knife work, and texture layering”, and (4) at no
time during the creation of each piece was an electromechanical process incorporated. The painting’s
dimensions are approximately 60” in length and 72” in height.
The ruling request seeks classification of the subject merchandise in subheading 9701.10.0000, Harmonized
Tariff Schedule of the United States, (HTSUS) and confirmation that the piece is not subject to the
International Emergency Economic Powers Act (IEEPA) tariffs.
The applicable subheading for the subject merchandise will be subheading 9701.91.0000, HTSUS, which
provides for “Painting, drawings and pastels, executed entirely by hand, other than drawings of heading 4906
and other than hand-painted or hand-decorated manufacture articles; collages, mosaics and similar decorative
plaques: Other: Paintings, drawings, and pastels.” The rate of duty will be free.
Trade Remedy:
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 India, will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within
an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. [9903.01.31], in addition to subheading 9701.91.0000, 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 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division