CLA-2-48:S:N:N8:234 803489
Ms. Barbara Lasher
A.N. Deringer, Inc.
P.O. Box 510
Sweetgrass, MT 59484
RE: The tariff classification of business forms and photographs,
from Canada; envelopes; marking.
Dear Ms. Lasher:
In your letter dated October 11, 1994, on behalf of your
client, Josten's Canada Ltd., you requested a tariff
classification ruling. Samples were submitted and will be
retained for reference.
The samples identified as "Grad Work Order" and "Schoolday
Job Ticket" are multi-page form sets, printed on self-copy paper,
with perforated stubs on the left and right sides. They are
headed by spaces for the entry of a school name/address, followed
by numerous captioned boxes, columns, lines, etc., intended for
the entry of details concerning student photography orders.
The applicable subheading for the "Grad Work Orders" and
"Schoolday Job Tickets" will be 4820.40.0000, Harmonized Tariff
Schedule of the United States Annotated (HTSUSA), which provides
for manifold business forms and interleaved carbon sets, of paper
or paperboard. The general rate of duty will be 5.3%. As these
articles are said to be for "internal use" by your client's
photographers, only the outermost container in which they are
imported need be marked with the country of origin.
The samples identified as "Services Packages" are small,
recloseable paperboard boxes (about 11" x 4" x 2 1/2") containing
a selection of items which your client can produce: photographic
prints in various formats (rolls, sheets, black & white, color)
and some plastic photo ID cards. The packages are said to be
used by Jostens' photographers as sales tools, i.e., to
illustrate offerings to clients.
The applicable subheading for the "Services Packages" will
be 4911.91.4040, HTSUSA, which provides for other (than certain
enumerated) printed pictures, designs and photographs. The
general rate of duty will be 3.1%. Since these articles are not
for sale, only the outermost container in which they are imported
need be marked with the country of origin.
The samples identified as "Memories You Won't Forget" and
"Envelope #1" are large paper envelopes, incorporating clear
cellophane windows, which will be imported containing student
photographs. The words "Made in Canada," or "Product of Canada,"
appear in the lower right corner of the backside of each sample
envelope. You explain that photographs are inserted into the
envelope for the student who is purchasing the package. All
packages destined for a common school are then boxed and shipped
in bulk to the school. The school then removes the packages and
distributes them to the students.
The applicable subheading for the "Memories You Won't
Forget" and "#1" photographs-in-envelope packages will be
4911.91.4040, HTSUSA, as described above, with a general rate of
duty of 3.1%. The country of origin marking represented by the
samples will be acceptable.
The last samples are paperboard envelopes containing student
photographs accompanied by suitable folding paperboard frames.
The outside of each recloseable envelope flap is marked "Product
of Canada." You explain that these products are complete
packages Jostens ships directly to the U.S. student. The
envelopes are shipped in bulk across the border, then separated
and mailed to the student's home address.
The applicable subheading for the paperboard envelope/
photograph/frame packages will be 4911.91.4040, HTSUSA, as
described above, with a general rate of duty of 3.1%. The
country of origin marking represented by the samples will be
acceptable.
This ruling is being issued under the provisions of Part 177
of the Customs Regulations (19 CFR 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport