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NY L80476




January 21, 2005

CLA-2-48:RR:NC:SP:234 L80476

CATEGORY: CLASSIFICATION

TARIFF NO.: 4811.51.2050; 4810.19.2090

Ms. Lisa Thatcher
Avery Dennison Office Products N.A.
50 Pointe Drive
Brea, California 92821

RE: The tariff classification of sign making kits from Mexico.

Dear Ms. Thatcher:

In your letter dated October 13, 2004, you requested a tariff classification ruling on five products. New York Ruling L80478, concerning three of the five products listed in your request, was issued to you on October 28, 2004. The present ruling, which was delayed by laboratory analysis of certain samples, will address the remaining two items.

SKU #7278202700, identified as a “White Display Board Sign Kit,” consists of the following items put up together for retail sale: one 24” x 36” sheet of corrugated paperboard, ten 8½” x 11” self-adhesive, matte-white plastic sheets, a software CD, and printed instructions. The corrugated paperboard is meant to serve as a backer for a sign to be made by the purchaser of this kit. The self-adhesive plastic sheets are designed to be printed (on a desktop laser or inkjet printer) with desired graphics, then stuck onto the paperboard backer to create the sign. The software CD includes numerous images, pre-formatted designs and printing templates that can help the user obtain professional-looking results.

For tariff classification purposes, the above-described kit will be regarded as “goods put up in sets for retail sale” whose essential character is imparted by the 24” x 36” paperboard backer. This backer, which has been folded in half along a partial slit, consists of an unbleached fluted core with a bleached (white) face sheet on each side. It has an overall thickness of about 2 mm. One of the white exterior surfaces, which is somewhat glossier than the other, is printed with guide lines intended to help the user position the self-adhesive plastic sheets. The New York Customs Laboratory finds that the paperboard weighs 889.2 grams per square meter, and is coated with a plastic material on one side and with an inorganic substance on the other side.

The applicable subheading for the complete #7278202700 kit will be 4811.51.2050, Harmonized Tariff Schedule of the United States (HTS), which provides for: Paper and paperboard, coated, surface-decorated or printed : coated, impregnated or covered with plastics (excluding adhesives): Bleached, weighing more than 150 g/m2: In strips or rolls of a width exceeding 15 cm or in rectangular (including square) sheets with one side exceeding 36 cm and the other side exceeding 15 cm in the unfolded state: 0.3 mm or more in thickness: Other (than certain enumerated kinds). The rate of duty will be Free.

SKU #7278202701, identified as a “Poster Sign Kit,” is similar to the kit described above, but in this instance the backers provided are in the form of two 18” x 24” sheets of non-corrugated white paperboard, each approximately 0.6 mm thick and printed on one side with guide lines. Ten sheets of 8½” x 11” self-adhesive white plastic, a software CD, and instructions are again included.

This kit will be regarded as “goods put up in sets for retail sale” whose essential character is imparted by the 18” x 24” paperboard backer sheets. In this instance, the lab finds that the paperboard is composed of chemical bleached kraft pulp fibers, weighs 409 grams per square meter, and is coated on both sides with an inorganic substance.

The applicable subheading for the complete #7278202701 kit will be 4810.19.2090, HTS, which provides for: Paper and paperboard, coated on one or both sides with kaolin (China clay) or other inorganic substances, with or without a binder, and with no other coating, whether or not surface-colored, surface-decorated or printed : Paper and paperboard of a kind used for writing, printing or other graphic purposes, not containing fibers obtained by a mechanical or chemi-mechanical process or of which not more than 10 percent by weight of the total fiber content consists of such fibers: Other (than certain enumerated kinds): Weighing more than 150 g/m2: Other than coated on one side only. The rate of duty will be Free.

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 Carl Abramowitz at 646-733-3037.

Sincerely,

Robert B. Swierupski
Director,

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