CLA-2-49:OT:RR:NC:5:130
Ms. Jen McLaughlan
BibNumbers.com
21 Concourse Gate Unit 8
Nepean, Ontario K2E 7S4
Canada
RE: The tariff classification of polyester bike plates and lanyard cards Canada
Dear Ms. McLaughlan:
In your letter, dated November 7, 2025, you requested a tariff classification ruling polyester printed bike
plates and lanyard cards. Product information and photos were submitted for our review.
The first product under consideration is a polyester (plastic), printed bike plate. The plastic is printed with a
large participant number and the Bibnumbers.com contact information. The plate is meant to be attached to a
bicycle to identify a participant in a race. The second product is a polyester (plastic), printed lanyard card.
The card is printed with the users first and last name, a QR code, “All Access”, and the Bibnumbers.com
contact information. The card is worn on a lanyard for users to be permitted to restricted areas during an
event. For both items, the printing is the principal element.
In your letter, you suggest that the plates and cards are classifiable in heading 3920.63. We disagree. Per
Chapter 39 Note 10 “plates, sheets, film, foil and strip” of heading 3920 must be rectangular in shape and
cannot be further worked. Your products have rounded corners as well as punched holes which indicate
further work. Therefore, the product is excluded from classification in 3920.63 HTSUS. Additionally, the
essential nature and use of the plates and cards is determined by the fact of its being printed with motifs,
characters or pictorial representations.
The applicable subheading of the polyester printed bike plates and lanyard cards will be 4911.99.8000,
HTSUS, which provides for Other printed matter, including printed pictures and photographs: Other: Other:
Other: Other. The general rate of duty will be free.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty.
However, goods classifiable in Chapter 49, HTSUS, are considered to be “informational materials” exempt
from these duties. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.12,
in addition to subheading 4911.99.8000, 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 Canada are not
subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e., 9903.01.26, in addition to subheading 4911.90.8000, 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 can be found 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division