CLA-2-37:OT:RR:NC:N3 135
Robert Vale
Strauns Customhouse Brokers LLC.
309 Pete Diaz Jr Ave Rio Grande City, TX 78582
RE: The tariff classification of thermal transfer ribbons from Mexico
Dear Mr. Vale:
In your letter dated July 18, 2024, you requested a tariff classification ruling on behalf of your client, Dynic USA. Additional information was provided via email dated July 22 and July 23, 2024.
The products under consideration are thermal transfer ribbons in rolls. They consist of a thin layer of plastic film coated with an ink (a color pigment, such as black or any other single color) transfer layer on one side and a backside coating.The thermal transfer ribbons will be imported in jumbo rolls and in smaller sizes.The width of a jumbo roll will be 910 millimeters (mm) and the length will exceed 15,000 meters. The smaller rolls are wound around a cardboard core, measuring 31 (mm) to 105 mm in width, or 106 mm to 601 mm in width. The length of the rolls varies from 74 meters to 1,000 meters. The thermal transfer ribbons are for use with thermal transfer ribbon printers.
The applicable subheading for the jumbo rolls of thermal transfer ribbons will be 3702.42.0100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for [p]hotographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles : [o]ther film, without perforations, of a width exceeding 105 mm: [o]f a width exceeding 610 mm and of a length exceeding 200 m, other than for color photography. The rate of duty will be 3.7% ad valorem.
The applicable subheading for the thermal transfer ribbons, if imported in a width not exceeding 105 mm will be 3702.39.0100, HTSUS, which provides for [p]hotographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles : [o]ther film, without perforations, of a width not exceeding 105 mm: [o]ther. The rate of duty will be 3.7% ad valorem.
The applicable subheading for the thermal transfer ribbons, if imported in a width exceeding 105 mm but not exceeding 601 mm will be 3702.44.0160, HTSUS, which provides for [photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles : [o]ther film, without perforations, of a width exceeding 105 mm: [o]f a width exceeding 105 mm but not exceeding 610 mm: [o]ther. The rate of duty will be 3.7% ad valorem.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division