CLA-2-49:OT:RR:NC:5:130
Mr. Thomas Seidler
Noteology Limited
71-75 Shelton Street
London WC2H 9JQ
United Kingdom
RE: The tariff classification of piano overlays from China
Dear Mr. Seidler:
In your letter, dated July 10, 2025, you requested a tariff classification ruling on printed, die-cut piano
overlays. Product information and photos were submitted for our review.
The item under consideration is printed piano overlays. The overlays are constructed of thick paperboard that
has been printed lithographically with keys, note names, and images on one side. The paperboard is
varnished and die-cut to rectangular shape. The cards are laid on top of a piano keyboard, aligning with the
keys, to teach users note names and locations, sight reading, and memorization. The cards are utilized in
conjunction with a computer app for learning. The graphic images on the cards are associated with the app’s
function. The cards are marketed to music teachers.
The applicable subheading for the piano overlays will be 4911.99.6000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Other printed matter: Other: Other: Other: Printed on paper in
whole or in part by a lithographic process. The column one, general rate of duty will be free.
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. Merchandise classifiable under subheading 4911.99.6000, 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 subheading 9903.01.22, HTSUS. At the
time of entry, you must report the applicable Chapter 99 subheading, 9903.01.22, in addition to subheading
4911.99.6000, 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. Products from all countries will be subject
to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading, as it
constitutes “informational materials”. At the time of entry, you must report the Chapter 99 subheading
applicable to your product classification, 9903.01.31, in addition to subheading 4911.99.6000, HTSUS, listed
above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4911.99.6000, 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 4911.99.6000, 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 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)
James Forkan
Acting Director
National Commodity Specialist Division