CLA-2-48:OT:RR:NC:N5:130
Mrs. Ling Raaby Warlow
Dragonfly Couture Stationery Ltd.
Studio 3, 3 Wood Street
Wirral, CH47 2DU
United Kingdom
RE: The tariff classification of a paper flower-making kit from Italy
Dear Mrs. Warlow:
In your letter, dated August 3, 2026, you requested a binding tariff classification ruling on a paper
flower-making kit. Product information and photos were submitted for our review.
The product under consideration is a craft kit for making crepe paper flowers. The kit comes in various
styles. The kit contains between four and eight rectangular sheets of color, creped paper, 6 to 12 7-inch
pieces of florist’s steel wire, and printed instructions and templates. The retail customer provides scissors
and glue and cuts the paper and assembles the flowers in accordance with the instructions. The paper is
manufactured in Italy and is not kraft paper.
The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the
official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI)
3(b) provides: “for the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to
mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different
headings; (b) consist of products or articles put 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 (e.g., in boxes or
cases or on boards).” Sets are classified according to the component, or components taken together, which
can be regarded as conferring on the set as a whole its essential character.
The flower kits consist of crepe paper and steel wire, which are classifiable in different headings. They are
put up together to make paper flowers and are packaged for retail sale. Therefore, the flower-making kits are
“goods put up in sets for retail sale”. The essential character is imparted by the crepe paper, which forms the
greatest surface area of the finished flowers.
The applicable subheading for the paper flower-making kits will be 4808.90.2000, HTSUS, which provides
for Paper and paperboard, corrugated (with or without glued flat surface sheets), creped, crinkled, embossed
or perforated, in rolls or sheets, other than paper of the kind described in heading 4803: Other: Creped or
crinkled. The general rate of duty will be free.
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 Laurel Duvall at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division