CLA-2-RR:OT:RR:E:NC:N1:106

Ryan Rolla, Product Manager
CRI2000, LP
2245 San Diego Ave
San Diego, CA 92110

RE: The tariff classification of paper cutting system from China

Dear Mr. Rolla:

In your letter dated October 17, 2008, you requested a tariff classification ruling.

The item under consideration has been identified as the Cutting Edge® Desktop Cutting System; a 2-in-1 combination guillotine and rotary paper cutter combo. You state that this is a retail item and will be sold in a single box.

The body of the base unit is ABS plastic, with a PP/TPE covered handle. It has two storage compartments, 1 large, 1 small, and a rotary blade storage compartment. The top of the large storage compartment is covered with a cutting mat that is printed with imperial and metric units for measuring cuts. There are two detachable cutters that lock onto the base unit. The first is a guillotine cutting attachment, which consists of a metal blade with PP/TPE handle. There is also a Rotary paper cutter attachment, with an ABS PP/TPE handle; this is a circular steel blade that moves back and forth on a track, allowing precision straight line cuts. There are also 3 different interchangeable blades, wave, pinking, perforating that are stored in the base unit.

The applicable subheading for the Cutting Edge® Desktop Cutting System will be 8441.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other machinery for making up…paper or paperboard, including cutting machines of all kinds,…: cutting machines. The general 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 World Wide Web at http://www.usitc.gov/tata/hts/.

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 Mark Palasek at (646) 733-3013.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division