CLA-2-39:RR:NC:SP:221 D80512
Mr. Jeff Holshevnikoff
Image World, S.A.
Interlink 782
P.O. Box 02-5635
Miami, FL 33102
RE: The tariff classification of printed self-adhesive vinyl sheets
from Costa Rica and Mexico.
Dear Mr. Holshevnikoff:
In your letter dated July 21, 1998, you requested a tariff classification
ruling.
Image World, S.A., of Costa Rica imports vinyl sheets (36" by 150' rolls),
clear plastic over-laminate (also 36" by 150' rolls) and ink. These products
are all made in the United States. Image World, using American made printing
machinery, then electrostatically prints an image on the vinyl. Using American
made laminating machinery, Image World then applies the laminate as a protective
layer. A similar operation is performed in Mexico, except that the printed
image is applied through screen printing. In both instances, the printed rolls
are then cut to specific size and shipped back to the United States in boxes.
The printed panels are typically applied to the sides of buses and trucks for
advertising or fleet marking.
The applicable subheading for the printed vinyl adhesive sheets will be
3919.90.5060, Harmonized Tariff Schedule of the United States (HTS), which
provides for self-adhesive plates, sheets, film, foil, tape, strip and other
flat shapes, of plastics...other. The duty rate will be 5.8 percent ad valorem.
Articles which are classifiable under subheading 3919.90.5060, HTS, which
are products of Costa Rica are entitled to duty free treatment under the
Generalized System of Preferences (GSP) upon compliance with all applicable
regulations, if the GSP is renewed.
Alternatively, products which are classifiable under subheading
3919.90.5060, HTS, which are the products of Costa Rica are entitled to duty
free treatment under the Caribbean Basin Economic Recovery Act (CBERA) upon
compliance with all applicable regulations.
You provided a sample of film that has been printed with a bird. The
printed sample is a product of Costa Rica, and upon compliance with applicable
regulations, such film will be eligible for duty free treatment under the CBERA,
or under the GSP, if the GSP is renewed.
However, it is not clear that all electrostatically printed film you plan
to import from Costa Rica can be considered products of Costa Rica. The film
itself is a product of the United States. In order for the printed film to be
considered a product of Costa Rica, the film will have to have undergone a
substantial transformation. You mention that the film will be used for bus and
truck fleet identification. Merely printing company logos on a film does not
substantially transform the film. Please provide samples and descriptions of
the printed film.
This ruling is being issued under the provisions of Part 177 of the Customs
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, contact National
Import Specialist Joan Mazzola at 212-466-
5580.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division