CLA-2-84:OT:RR:NC:N1:105
Jacquelyn Votra
Trans-Border Global Freight Systems
2103 Route 9
Round Lake, NY 12151
RE: The tariff classification of a flatbed laminator from Norway
Dear Ms. Votra:
In your letter dated September 19, 2025, on behalf of your client, Rollover AS, you requested a tariff
classification ruling. Descriptive literature was provided for our review.
The item under consideration is described as the Rollover Flatbed Laminator, which operates as a
pressure-activated, bubble-free application table that uses a manually controlled, antistatic rubber roller on an
illuminated glass bed to smoothly apply self-adhesive films, laminates, and prints onto various flat substrates.
The roller is moved over the material and substrate, which is placed on the illuminated cutting mat, using
handles for one-handed operation. This design allows for accurate, one-pass application and eliminates the
need for traditional, potentially bubbly manual methods, with the illumination improving accuracy for tasks
like weeding and cutting.
The machine features a single roller and can be configured with either 4 or 8 fixed legs, or with height
adjustable legs equipped with locking wheels for positioning within a workspace. The device also has tool
pockets on each housing for safety knives and tape measures. Additionally, there is a separate outlet for an air
gun connection and handy holders where media spindles/brackets are mounted. Furthermore, the table has an
integrated air pressure gauge, self-healing cutting mat, and illuminated glass bed (LED). Its primary purpose
is laminating, but it is capable of performing other tasks such as serving as a pre-mask applicator, a weeding
table, or a backlit workstation. The laminator is marketed to sign makers, print shops, brand departments,
automotive and marine industries, car wrapping professionals, and municipalities.
Based on the information provided, we believe the Rollover Flatbed Laminator to be a composite machine
per Section XVI Note 3, which states: Unless the context otherwise requires, composite machines consisting
of two or more machines fitted together to form a whole and other machines designed for the purpose of
performing two or more complementary or alternative functions are to be classified as if consisting only of
that component or as being that machine which performs the principal function. In this case, we find the
laminating function to be the principal function.
Accordingly, the applicable subheading for the Rollover Flatbed Laminator will be 8420.10.9040,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Calendering or other rolling
machines, other than for metals or glass, and cylinders therefor; parts thereof: Calendering or other rolling
machines: Other: Calendering or other rolling machines for rubber and plastics.” The general 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 of Norway will be
subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.50, in addition to subheading
8420.10.9040, 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 Jason Christie at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division