CLA-2-95:OT:RR:NC:N4:424
Kelly Alm
Majestic Trinity Foundation
520 West 7th Avenue - 407
Vancouver, British Columbia
Canada, V5Z 1B3
RE: The tariff classification, country of origin, and marking, of religious themed playing cards from
Canada
Dear Ms. Alm:
In your letter dated January 14, 2026, you requested a binding ruling on the tariff classification, country of
origin, and marking, of religious themed playing cards imported from Canada.
A sample of the Majestic Trinity Card Set, item number MTICS2025 Legacy Blue Back, was received with
your inquiry.
The subject merchandise is a religious themed deck of 73 standard size playing cards. The cards are printed
with various scripture texts and are used in playing card games including solitaire. Game instructions are
included in the retail packaging, and the consumer is encouraged to create their own games. The cards are
intended to educate the player with Christian scripture.
Classification:
In your letter, you suggest that the playing cards are classifiable under subheading 9810.00.3500,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for the duty-free entry of articles
(including letters, numbers, other symbols, and printed matter) imported for the use of any public library or
any other public or nonprofit institution established for educational purposes. Such articles must be
exclusively for the use of the institution involved, and not for distribution, sale or other commercial use
within five years after being entered. To be eligible for this provision, the articles must be designed for a
specific course of study involving classroom instruction of children. They must also be imported by or upon
the order of the nonprofit institution. (This may be certified at time of entry by a letter from the
organization.) You state that the playing cards will be sold on eBay and other online sites directly to
consumers. The mere expectation of a possible future sale to a nonprofit institution would not qualify a
shipment for free entry under this provision.
The applicable subheading for the Majestic Trinity Card Set card game will be 9504.40.0000, HTSUS, which
provides for "Video game consoles and machines, articles for arcade, table or parlor games…parts and
accessories thereof: Playing Cards." The rate of duty will be Free.
Country of Origin and Marking:
The manufacturing processes used to produce the Majestic Trinity Card Set are as follows:
Paper card stock is manufactured in the United States and imported into Canada in rolls.
In Canada, the card stock rolls are printed on both sides, die cut into playing cards, and packaged for retail
sale.
The completed card decks are imported into the United States.
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States 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 United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of
manufacture, production, or growth of any article of foreign origin entering the United States. Further work
or material added to an article in another country must effect a substantial transformation in order to render
such other country the “country of origin” within the meaning of the marking laws and regulations.
Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other
USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in
sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect
to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining
the country of origin of a good for marking purposes, with the exception of textile and apparel goods which
are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11.
Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in
which:
(1) The good is wholly obtained or produced;
(2) The good is produced exclusively from domestic materials; or
(3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set
out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable
requirements of these rules are satisfied.
“Domestic material” is defined in 19 C.F.R. § 102.1(d) as “a material whose country of origin as determined
under these rules is the same country as the country in which the good is produced.” “Foreign material” is
defined in 19 C.F.R. § 102.1(e) as “a material whose country of origin as determined under these rules is not
the same country as the country in which the good is produced.” Here, 102.11(a)(1) and 102.11(a)(2) do not
apply because the product will neither be wholly obtained or produced nor produced exclusively from
“domestic” (Canadian, in this case) materials. Accordingly, pursuant to 102.11(a)(3), the non-Canadian
material must meet the applicable change in tariff classification set out in Section 102.20 in order for the
product to qualify to be marked as a product of Canada.
As set out in 19 CFR 102.20, the rule of origin applicable to goods classified in heading 9504, HTSUS
requires:
A change to heading 9504.20 through 9506.29 from any other subheading, including another subheading
within that group.
Since the foreign material used to produce the cards (namely, the paper card stock) is classified outside the
tariff range of 9504.20 through 9506.29, the Majestic Trinity Card Set will undergo the requisite tariff shift
cited above. Therefore, the country of origin of the playing cards for marking purposes will be Canada.
As the country of origin for this product is Canada, it must be marked “Made in Canada” in accordance with
the applicable statute and regulations.
Trade Remedies:
When determining the country of origin for purposes of applying current trade remedies under Section 301
and other duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter
H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur
is whether an article emerges from a process with a new name, character, or use different from that possessed
by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A.
1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United
States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
In regard to the Majestic Trinity Card Set, we find that a substantial transformation occurs in Canada.
It is therefore the opinion of this office that the country of origin of the Majestic Trinity Card Set is Canada
for Section 301 and other duties.
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 Irene Tsiavos at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division