CLA-2-44:OT:RR:NC:N5:130
Ms. Oana Agache
Happy Project Event S.R.L.
Str. Domneasca, Nr. 119
Galati, Galati County 800201
Romania
RE: The tariff classification of a wooden decorative plaque from Romania
Dear Ms. Agache:
In your letter, dated February 25, 2025, you requested a binding tariff classification ruling on a wooden
decorative plaque. Product information and photos were submitted for our review.
The product under consideration is a decorative plaque constructed of medium density fiberboard (MDF) and
plywood. The various styles of plaque measure from 12” x 9” to 30” x 24”. The back panel is constructed of
MDF, and laser-cut poplar plywood pieces are glued onto the front of the panel. The plaque is hand-painted
and may be laser-engraved. Each plaque is personalized; the sample photo shows the silhouette of a couple
next to a tree with several cut leaf shapes. There are also laser-cut names, “Matthew and Loretta April 19,
2025”. The plaque is imported with two permanent markers with which individuals can write messages on
the plaque, and a plywood stand to hold the plaque upright on a shelf. The plaque may be imported with a
smaller, laser-engraved plaque with a message such as “Please sign our guest book.”
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance
with the General Rules of Interpretation (GRIs). The Explanatory Notes, which constitute the official
interpretation of the HTSUS at the international level, state in Note (X) to GRI Rule 3 (b) that the term
"goods put up in sets for retail sale" means goods that: (a) consist of at least two different articles which are,
prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need
or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without
repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component
which gives them their essential character, which may be determined by the nature of the material or
component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of
the article.
The pens are classified in a different heading than the plaques and the stand, and while you have not provided
images of the packaging, it is clear that the plaques are purchased at retail. The components all support the
plaque and go toward the activity of personalizing and displaying the plaque. Therefore, we find that the
items meet the term “goods put up in sets for retail sale”. The plaque imparts the essential character of the
set.
The applicable subheading for the plaque set is 4420.19.0000, HTSUS, which provides for Wood marquetry
and inlaid wood; caskets and cases for jewelry or cutlery and similar articles, of wood; statuettes and other
ornaments, of wood; wooden articles of furniture not falling within chapter 94: Statuettes and other
ornaments: Other. The general rate of duty is 3.2 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 Laurel Duvall at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division