CBP Affirms Classification Ruling on Scrapbook Letter Stickers With Printed Designs
Chipboard letters with printed designs for use in scrapbooks are correctly classified as their constituent material paperboard, and not as printed designs on paperboard, said CBP as it affirmed an earlier tariff classification ruling. The shape of the letters is the most important aspect of the product, and not the printed designs, CBP said.
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The chipboard letters are one of three different types of die-cut chipboard shapes designed to be used in scrap booking. These were uppercase letters printed with designs, argyle, dots, and stripes. They had self-adhesive backs. Evans and Wood requested the earlier ruling on behalf of its client Hobby Lobby Stores. In response, CBP issued HQ N056181 (here) on April 29, 2009, finding the chipboard letters to be classified under Harmonized Tariff Schedule subheading 4823.90.86 (“Other paper, paperboard, cellulose wadding and webs of cellulose fiber, cut to size or shape …: Other: Other: Other: Other: Other”).
Evans and Wood requested that CBP reconsider. The customs broker said classification of the stickers as paperboard was inconsistent with a CBP informed compliance publication called “Decals, Decorative Stickers and Window Clings” from January 2007 (here). There, CBP said the difference between classification as a printed paper or paperboard label under heading 4821, and a decorative sticker under 4911, was whether the principal use is decorative or utilitarian. The chipboard stickers are decorative, and should be classified under heading 4911, Evans and Wood said.
CBP disagreed on July 31 in ruling HQ H072716 (here). The patterns printed on the letters are “merely incidental” to the shape of the letters, the agency said. The letters are made of chipboard, a type of paperboard, and so should be classified as paperboard in heading 4823, CBP said.