CLA-2-49:OT:RR:NC:5:130
Mr. Schuyler Schouten Jones Day 4655 Executive Drive San Diego, CA 92121 RE: The tariff classification of greeting cards and calendars from China and Vietnam Dear Mr. Schouten: In your letter, dated September 19, 2025, you requested a binding tariff classification ruling on behalf of your client, Minted LLC. The ruling request was for the classification of greeting cards and calendars. Product information and photos were submitted for our review. The greeting cards, which measure 5”x7”, are folded and are printed with illustrations on the front. The first is printed on the front with “Merry Christmas” and has a raised, printed Santa’s sleigh and reindeer. The second is printed with a full Christmas stocking and has the word “Joy” across the front. The third is color printed with animals and says “Happy Birthday” across the front. The cards are blank inside. The calendar consists of 12, 5”x5” pieces of paper, each printed with a month of the year. The 12 pieces of paper sit on a small wooden stand. You indicate that the calendar measures under 0.51mm in thickness. The applicable subheading for the greeting cards will be 4909.00.4000, Harmonized Tariff Schedule of the United States (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 general rate of duty will be free. Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). The Explanatory Notes, which constitute the official interpretation of the HTSUS at the international level, state in Note (X) to GRI Rule 3 (b) that the term "goods put up in sets for retail sale" means goods that: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without
repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. The calendars and wooden stand are classifiable in different headings, they are packaged together for retail sale, and they carry out the specific activity of displaying a calendar. Therefore, they qualify as “goods put up is sets for retail sale”. The calendar imparts the essential character of the set. The applicable subheading for the calendar will be 4910.00.2000, HTSUS, which provides for Calendars of any kind, printed, including calendar blocks: Printed on paper or paperboard in whole or in part by a lithographic process: Not over 0.51 mm in thickness. The 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. Goods classifiable under 4909.00.4000 and 4910.00.2000, HTSUS, constitute “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 subheadings 4909.00.4000 and 4910.00.2000, 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 China, Hong Kong, and Macau will be subject to an additional 10 percent ad valorem rate of duty. As noted above, goods classifiable under subheadings 4909.00.4000 and 4910.00.2000, HTSUS, are considered informational materials. At the time of entry, you must report the Chapter 99 subheading applicable to your product classification, 9903.01.24, in addition to subheadings 4909.00.4000 and 4910.00.2000, 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. At this time, products of Vietnam will be subject to an additional ad valorem rate of duty of 20 percent. As noted the calendar and greeting cards are informational materials and fall 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, HTSUS, in addition to subheadings 4909.00.4000 and 4910.00.2000, 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. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division