CLA-2-39:OT:RR:NC:N5: 137
Carolyn Leski
BCB International Inc
1010 Niagara St
Buffalo, NY 14213
RE: The tariff classification of metallized polyethylene terephthalate (PET) radiant barrier sheets from
Canada
Dear Ms. Leski:
In your letter dated January 9, 2026, you requested a tariff classification ruling on behalf of your client,
Balcan Innovations, Inc.
The products under consideration are referred to as 4800 Series NT Radiant Barrier sheets. The products have
a total finished weight of 0.148 kg/m2. The plastic material constitutes 55 percent of the total weight of the
sheets. These are described as high-performance reflective insulation intended for use as an insulation or
vapor barrier in a variety of construction applications.
Part Numbers 4800-48-125S and 4800-48-250S are solid sheet products. The products are composed of a
coated woven fabric composed of high-density polyethylene (HDPE) fabric coated on one side with a layer
of low-density polyethylene (LDPE). This coated fabric is sandwiched between two layers of metallized
polyethylene terephthalate. The metallization is applied by vapor deposition.
Part Numbers 4800-48-125P and 4800-48-250P are perforated sheet products. These perforated sheet
products are manufactured in the same way as the solid sheet products. However, these sheets undergo
additional manufacturing steps to incorporate the perforation.
You suggest classification of these products in 3920.62.0050, Harmonized Tariff Schedule of the United
States (HTSUS). We disagree. Heading 3920 covers other sheets of plastic that are not reinforced, laminated,
supported or combined with other materials. These products contain a center layer of coated textile fabric.
Therefore, the sheets are excluded from classification in 3920.62.0050, HTSUS. Further, headings 3920 and
3921, HTSUS, exclude products that have been further worked. Perforation constitutes further work and
therefore, the perforated sheets are excluded from classification in 3920, HTSUS and 3921, HTSUS.
The applicable subheading for the metallized PET solid radiant barrier sheets, 4800-48-125S and
4800-48-250S will be 3921.90.1500, HTSUS, which provides for other plates, sheets, film, foil and strip, of
plastics: other: combined with textile materials and weighing not more than 1.492 kg/m2: products with
textile components in which man-made fibers predominate by weight over any other single textile fiber:
other. The general rate of duty will be 6.5 percent ad valorem.
The applicable subheading for the metallized PET perforated radiant barrier sheets, 4800-48-125P and
4800-48-250P will be 3926.90.9989, HTSUS, which provides for other articles of plastics and articles of
other materials of headings 3901 to 3914: other: other: other. The general rate of duty is 5.3 percent ad
valorem.
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/.
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 Christina Allen at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division