CLA-2-84:OT:RR:NC:N1:105
Christin Madro
Acco Brands USA LLC
4 Corporate Drive
Lake Zurich, IL 60047
RE: The tariff classification of a Reloadable Cartridge Refill from China
Dear Ms. Madro:
In your letter dated December 16, 2020, you requested a tariff classification ruling.
The item under consideration is identified as a Reloadable Cartridge Refill, which consists of two rolls of lamination film that are held together by a proprietary plastic transfer piece housing and handle. The transfer piece serves to hold and separate the two rolls of film, and together works as an essential part to supply the laminated film to the lamination machine during operation. The refill unit is specifically made to be used with the reusable plastic cartridge carrier (not included) and cannot be used for any other application.
Similar to the LC-D9 refill cartridges in HQ 966166 (dated May 9, 2003), the Reloadable Cartridge refills are classifiable, pursuant to Section XVI, note 2(b), Harmonized Tariff Schedule of the United States (HTSUS), in subheading 8420.99, HTSUS, as parts of calendering or other rolling machines. The reloadable cartridge refills cannot be used with any other device and are designed specifically to fit in the reusable plastic cartridge carrier.
The applicable subheading for the Reloadable Cartridge Refill will be 8420.99.9000, HTSUS, which provides for “Calendering or other rolling machines, other than for metals or glass, and cylinders therefor: Parts: Other: Other”. The general rate of duty will be free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8420.99.9000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8420.99.9000, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.
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.
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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division