CLA-2-85:OT:RR:NC:N2:208
Benjamin Kellam
CPI Card Group
10368 Centennial Rd
Littleton, CO 80127
RE: The tariff classification of unfinished “smart cards” from Thailand
Dear Mr. Kellam:
In your letter dated April 24, 2026, you requested a tariff classification ruling.
The merchandise under consideration is RFID card inlay sheets. The sheets contain an array of RFID chips
and an antenna laminated in PVC plastic sheets that are used as components in the manufacturing process of
smart cards. As imported, the subject inlay sheets contain integrated circuits with unrecorded memory, which
constitute “semiconductor media.” Once these unfinished smart cards are completed when held in proximity
to a card reader, the radio field generated by the reader activates the chip, and the encrypted data stored on
the chip is transferred to the reader.
The applicable subheading for the subject RFID card inlay sheets will be 8523.52.0010, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Disc, tapes, solid-state non-volatile storage
devices, “smart cards” and other media for the recording of sound or of other phenomena, whether or not
recorded, including matrices and masters for the production of discs, but excluding products of Chapter 37:
Semiconductor media: “Smart cards”: unrecorded. 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 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 Lisa Cariello at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division