CLA-2:OT:RR:NC:N4:422
Mr. Scott Malone
Artabee
603 S. Public Rd #282
Lafayette, CO 80026
RE: The tariff classification of plastic picture frames from China
Dear Mr. Malone:
In your letter dated December 3, 2025, you requested a tariff classification ruling. Photographs were
submitted along with your request.
The merchandise under consideration is plastic picture frames, branded “Fitm.” The item is comprised of
six-rectangular plastic border photo frames. Each frame consists of an injection molded acrylonitrile
butadiene styrene (ABS) plastic body with a black and matte textured finish. The frame features molded press
fit connectors allowing consumers to assemble multiple frames into wall-mounted collages without the need
for tools. Each frame consists of a clear polyethylene terephthalate (PET) plastic front pane that serves as a
protective cover for the inserted photograph. An ethyl vinyl alcohol (EVA) foam backing is included for each
frame to hold the photograph securely against the PET pane. A small metal screw, plastic wall anchor, and
3M adhesive strip are included as optional mounting hardware. Each frame measures approximately 4 inches
long by 6 inches wide by 0.64 inches high for household display of standard 4×6 photographs or artwork.
The applicable subheading for the plastic picture frames will be 3924.90.2000, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for…other household articles…of plastics: other: picture
frames. The general rate of duty will be 3.4 percent ad valorem.
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 marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless
excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a
conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will
permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country
of origin of the article.
As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is
considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it
without strain. With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19
CFR 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into
the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles
be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44),
generally provides that any marking that is sufficiently permanent so that it will remain on the article until it
reaches the ultimate purchaser unless deliberately removed is acceptable.
From the photos submitted, the bottom of the box indicates with the country of origin printing the words,
“Made in China” on the first line, “Hergestellt in China” on the second line, “Fabriqué en Chine” on the third
line, “Prodotto in Cina” on the four line, “Gemaakt in China” on the fifth line, “Wyprodukowano w Chinach”
on the six line, “Fabricado en China” on the seventh line, and “Fabricado na China” on the eighth line.
Each line is printed at the bottom of the box. The country of origin marking is conspicuous to the ultimate
consumer. It is our opinion that a potential purchaser of the article would check the box before purchasing it.
As a result, this office agrees that plastic picture frames satisfy country of origin marking requirements.
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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division