CLA-2-84:OT:RR:NC:N1:118
Jeff Watkins
Inline Packaging LLC
1205 18th Avenue South
Princeton, MN 55371
RE: The tariff classification of a narrow body gravure roll from China
Dear Mr. Watkins:
In your letter dated October 6, 2026, you requested a tariff classification ruling. Product information was
submitted with your request.
The merchandise under consideration is identified as narrow body gravure roll, Inline part no. 201889. The
part is an intermediate stage in the production of a gravure cylinder, which is used in a rotogravure press.
The three components of the imported narrow body gravure roll consist of the rolled steel body and the two
steel side journals. Prior to importation, each component is machined to precise dimensions and parameters
to fit into the rotogravure press. The components will be imported, unassembled, in a single shipment. You
have stated that no journal or body will be imported separately, and that no spare pieces or other components
will be included in the shipment. After importation, the body and two journals will be assembled by means
of a heat shrink-fit process. Once assembled, the rolled portion is copper-plated and polished, the gravure
cell pattern is engraved into the copper, and the engraved surface is chrome-plated and finish-polished.
The finished gravure cylinder is then installed into the rotogravure press. The engraved cells of the gravure
cylinder pick up liquid from a pan, a doctor blade wipes off the excess, and the cylinder transfers the liquid to
the paper web at the nip with the impression roll. The journals carry the roll in the press bearings, and the
keyed journal is driven by the press.
Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in
accordance with the General Rules of Interpretation (GRIs). GRI 1 states in part that for legal purposes,
classification shall be determined according to the terms of the headings and any relative section or chapter
notes. GRI 2(a) extends the scope of the HTS headings to include unfinished parts, provided the unfinished
parts have the essential character of the finished parts. The body and two side journals will be imported as a
matched set and are assembled after importation by a simple heat shrink-fit process without further
machining. As such, we find that the unassembled body and side journals provide the essential character of
the narrow body gravure roll, Inline part no. 201889.
The applicable subheading for the narrow body gravure roll, Inline part no. 201889, will be 8443.91.3000,
HTSUS, which provides for printing machinery used for printing by means of plates, cylinders and other
printing components of heading 8442…parts and accessories: other. 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 Anthony Grossi at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division