The tariff classification of a decorative pallet with metal clips from China

N278858 September 29, 2016 CLA-2-44:OT:RR:NC:4:234 CATEGORY: Classification TARIFF NO.: 4421.90.9780 Ms. Tanya Laird Nielsen & Bainbridge 12303 Technology Blvd. Austin, TX 78727 RE: The tariff classification of a decorative pallet with metal clips from China Dear Ms. Laird: In your letter, dated August 24, 2016, you requested a classification ruling. The ruling was requested on a decorative wood pallet with metal clips. A photo was submitted for our review. The decorative wood pallet measures approximately 30” wide by 22” tall by 1.8” deep. While decorative, the pallet is constructed in a manner similar to a shipping pallet, with six horizontal wood slats affixed to three vertical boards. The pallet is painted a grey color and has movable metal clips affixed to its front. You state that there is metal hardware on the back and that the pallet is intended to be hung on a wall. Because the pallet is merely decorative and has no transportation and storage application, it is precluded from classification as a pallet in heading 4415, Harmonized Tariff Schedule of the United States (HTSUS). While you state that the clips are used to display photographs, the pallet is also not a wooden frame as classifiable in heading 4414, HTSUS. The frames of this heading are of a type that generally surround a picture, mirror, certificate, or similar item. The instant product, however, need not be used for displaying pictures; it could be used in a manner similar to a bulletin board to hang notes, cards, jewelry, or other items in addition to photos. The applicable subheading for the wooden pallet with metal clips will be 4421.90.9780, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other. The rate of duty will be 3.3 percent 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 on 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division