CLA-2-97:OT:RR:NC:N5:433
Michele Lehat
Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP
599 Lexington Ave, Fl 36
New York, NY 10022
RE: The tariff classification of an oil painting from Italy
Dear Ms. Lehat:
In your letter dated January 13, 2026, you requested a tariff classification ruling on behalf of Ms. Claudia
Springer. In lieu of samples, illustrative literature, and a description were provided. Additionally, we
acknowledge the opinions and observations provided by your independent expert in the field concerning the
piece.
Luciano Ventrone’s painting “La Compagnia Ventrone (The Company),” is a framed oil painting on canvas.
The painting’s image consists of various fruits, berries, and foliage in a basket. The painting includes tints
and shades of yellow, green, red, black, white, and other colors. The painting’s dimensions are approximately
50cm in length and 70cm in width. The submitted documentation states, the piece is “an original
oil-on-canvas artwork executed entirely by hand.” Further, documentation provided to establish provenance
includes (1) a certificate by Miranda Gibilisco of the Penta Art Gallery that conveys the piece is oil with
mixed media on linen canvas and (2) a certificate by Fondazione Luciano Ventrone Miranda Gibilisco ETS
registration number 0612006. At the time of importation into the United States, the oil painting will be
mounted to a wooden frame and will bear the signature of the artist in the bottom left corner of the piece.
The ruling request seeks classification of the subject merchandise in subheading 9701.91.0000, Harmonized
Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the subject merchandise will be 9701.91.0000, HTSUS, which provides for
“Painting, drawings and pastels, executed entirely by hand, other than drawings of heading 4906 and other
than hand-painted or hand-decorated manufacture articles; collages, mosaics and similar decorative plaques:
Other: Paintings, drawings, and pastels.” 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/.
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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division