CLA-2-48:OT:RR:NC:N4:434
TARIFF NO: 4817.20.4000
Mr. Schuyler Schouten
Jones Day
4655 Executive Drive
San Diego, CA 92121
RE: The tariff classification of note cards with envelopes from China & Vietnam
Dear Mr. Schouten:
In your letter, dated March 20, 2026, you requested a binding tariff classification ruling on behalf of your
client, Minted LLC, for note cards. Pr with envelopesoduct information and samples were submitted for our
review.
The item under consideration is described as “Mini Card Sets: Very Merry”, Uniform Product Code (UPC),
843740142421. The set of 12 note cards and envelopes are packaged together in a clear polypropylene bag.
The card set consists of 4 different designs. One design depicts Santa on a sleigh with 3 reindeers at the
bottom of the card. Another design depicts a red bow, lying diagonally across the two corners of the card.
The other two card designs have a thin colored border design with lines. The majority of the front of the
cards are blank and back of all the cards are blank to allow for written message. The cards are flat
(non-folding), measuring 2.75” x2.75”. You indicate the cards are 0.35mm thick and are printed
lithographically.
You propose classification in Chapter 49, Harmonized Tariff Schedule of the United States (HTSUS), as
printed material. We disagree.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the Harmonized System. While not legally binding nor dispositive, the ENs provide a
commentary on the scope of each heading of the Harmonized Tariff Schedule of the United States (HTSUS)
and are generally indicative of the proper interpretation of these headings.
The General EN to Chapter 49, HTSUS, provides in pertinent part: “With the few exceptions referred to
below, this Chapter covers all printed matter of which the essential nature and use is determined by the fact
of its being printed with motifs, characters or pictorial representations...” An exception referred to later in the
notes are goods “…in which the printing is merely incidental to their primary use (e.g. printed wrapping
paper and printed stationery) fall in Chapter 48.”
Therefore, we must also consider classification in chapter 48, HTSUS. Heading 4817, HTSUS, provides for
“Envelopes, letter cards, plain postcards and correspondence cards, of paper or paperboard; boxes, pouches,
wallets and writing compendiums, of paper or paperboard, containing an assortment of stationery.”
The ENs to Heading 4817, HTSUS, state “These articles may be printed with addresses, names, trademarks,
decorations, crests, initials etc., merely incidental to their use as stationery.” Therefore, this heading provides
for blank stationery items and those with printed elements that are merely incidental to their use as stationery.
The “Mini Card Sets” are “correspondence cards” as specifically provided for in the heading language of
heading 4817, HTSUS. Correspondence cards are further described in the ENs to heading 4817, HTSUS, as
follows: “Correspondence cards do not fall in this heading unless they have deckled or gilt edges or rounded
corners, or are printed or otherwise prepared in such a manner as to clearly indicate their use as stationery.”
The instant “Mini Card Sets” are printed or otherwise prepared and packaged with corresponding envelopes
indicating their use as stationery. The blank space on both the front and reverse allow for written
correspondence. As such, heading 4817, HTSUS, best describes the articles. The cards and envelopes
constitute a set for the purposes of GRI 3(b) and will be classified according to the item that imparts the
essential character, the cards.
The applicable subheading for the “Mini Card Sets: Very Merry”, Uniform Product Code (UPC)
843740142421 will be 4817.20.4000, HTSUS, which provides for “Letter cards, plain postcards and
correspondence cards: Other.” The 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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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)
James P. Forkan
Director
National Commodity Specialist Division