CLA-2-48:OT:RR:NC:4:434
Alice Lu
PrintX GP Factory Co. Ltd.
National Rd. #51, Trapeang Phlong Village
Damnak Reang Commune, Oudong District
Kampong Speu Province
CAMBODIA
RE: A tariff classification of padfolios from Cambodia
Dear Ms. Lu:
In your letter, dated September 3, 2021, you requested a tariff classification and country of origin ruling on padfolios. On behalf of your client, Lowe’s Companies. A partial description of the manufacturing operations and a sample of the item were submitted for our review.
The item under consideration is a padfolio, specifically the “Work Pad Folio,” item number 1059308.
The padfolio measures approximately 13” (L) x 10” (W) by 1.5” (D), when zipped closed, and is constructed of what appears to be plastic sheeting and cardboard covered with textile. The interior includes a slot into which an 8.5” x 11” lined writing pad has been inserted. The opposing interior cover incorporates an elastic pen loop, a small calculator, three small pockets for holding business cards or the like, and two vertical pockets for holding slim items, such as papers.
You state a belief that the padfolios are classified in subheading 4202.92.00, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Classification of goods under the HTSUS is governed by the General Rules of Interpretation (GRIs). A GRI 3(b) analysis of the composite good results in a determination that the essential character of the padfolio is imparted by the memo pad. We reference rulings HQ 951218, dated July 28, 1992, HQ 962030, dated May 13, 1999, and NY I87434, dated 10/30/02, that classified similar padfolios with calculators in heading 4820, HTSUS.
Therefore, the applicable subheading for the padfolio will be 4820.10.2020, HTSUS, which provides for: “Memorandum pads, letter pads and similar articles.” The rate of duty will be Free.
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 on the World Wide Web at https://hts.usitc.gov/current.
You further inquire about the country of origin for the finished padfolios. However, we received insufficient information in order to render a ruling on this topic. If you wish to pursue a country of origin ruling for this merchandise in the future, please include detailed information listing the country in which each raw material or subcomponent is manufactured and the value of each such material or subcomponent. Also provide a list of every production step and in what country these steps are carried out and the value of the manufacturing and overhead costs in each country.
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 Charlene Miller [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division