CLA-2-49:OT:RR:NC:N4:434
Kimberly Long
Reprodux Limited
1120 Brevik Pl
Mississauga L4W 3Y5
Canada
RE: The tariff classification and United States-Mexico-Canada Agreement (USMCA) eligibility of
advertising signage
Dear Ms. Long:
In your letter dated December 30, 2025, you requested a ruling concerning the tariff classification and United
States-Mexico-Canada Agreement (USMCA) eligibility of advertising signage. Representative photos and
product descriptions were provided for our review.
The products under consideration are printed point-of-sale signs for in-store advertising and promotional
display at retail locations. You identified four types of products: flat printed advertising signs, rigid or
semi-rigid printed display panels, counter or shelf advertising signage, and packaged retail signage kits
containing multiple printed signs and mounting hardware. You state that the signage is produced by printing
advertising graphics and text on paper substrates. You assert that the signs are not consumer goods and are
not sold at retail as merchandise.
Classification:
You propose classification of the advertising signs in subheading 4911.10.0080, Harmonized Tariff Schedule
of the United States (HTSUS), as printed trade advertising material. We agree. The essential nature and use
of the product is conferred by the printed advertisement.
The applicable subheading for the flat printed advertising signs, rigid or semi-rigid printed display panels,
and counter or shelf advertising signage will be 4911.10.0080, HTSUS, which provides for Other printed
matter, including printed pictures and photographs: Trade advertising material, commercial catalogs and the
like: Other. The general rate of duty will be free.
The 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/.
In your letter, you outline a scenario where paper of U.S. or Canadian origin is printed with advertising
graphics and text using printing ink sourced from Belgium onto the paper substrates, followed by cutting,
finishing and assembling into signage in Canada.
USMCA:
The United States-Mexico-Canada Agreement (USMCA) was signed by the Governments of the United
States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with
the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14
(19 U.S.C. § 4511(a)). General Note (“GN”) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth
the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b)
states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a “good originating in the territory of a USMCA country” only if-
(i)the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
(ii)the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials;
(iii)the good is a good produced entirely in the territory of one or more USMCA countries
using non-originating materials, if the good satisfies all applicable requirements set forth in
this note (including the provisions of subdivision (o));
Since the flat printed advertising signs, rigid or semi-rigid printed display panels, and counter or shelf
advertising signage contain non-originating material, they are not considered goods wholly obtained or
produced entirely in a USMCA country under GN 11(b)(i) and (ii). We must next determine whether the
advertising signage qualifies under GN 11(b)(iii). As the imported advertising signage is classified in heading
4911, HTSUS, the applicable rule of origin is in GN 11(o), HTSUS, which provides, in relevant part: Chapter
49: A change to headings 4901 through 4911 from any other chapter.
In this case, only the printing ink originates outside the USMCA territory, and it is classifiable in heading
3215, HTSUS, upon importation into Canada. After manufacturing in Canada, the final product is
classifiable in heading 4911, HTSUS. Therefore, the tariff-shift rule is met. Accordingly, the flat printed
advertising signs, rigid or semi-rigid printed display panels, and counter or shelf advertising signage,
classified under subheading 4911.10.0080, HTSUS, are eligible for preferential tariff treatment under the
USMCA upon compliance with all applicable laws, regulations, and agreements.
Your inquiry does not provide enough information for us to give a classification and USMCA eligibility
determination ruling on the signage kits. Your request for the ruling should identify all items in the signage
kit, material composition and the country of origin of each item. Please identify the mounting hardware.
Please provide pictures of the mounting hardware from all angles. Identify the country of origin of the
mounting hardware. Provide the industry standard to which the mounting hardware/fasteners are produced
(if applicable). For screws and bolts, provide the diameter of the shanks or threads. Are they imported with
their nuts and/or washers? Identify the type of drive and point. When this information is available, you may
wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you
decide to resubmit your request, please include all of the material that we have returned to you.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 Susana Li at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division