The tariff classification of “Prism” guided corporate exercises from China

N352320 August 29, 2025 CLA-2-49:OT:RR:NC:5:130 CATEGORY: Classification TARIFF NO.: 4911.99.6000; 9903.01.22; 9903.01.31; 9903.88.15 Dr. Daniel Epstein Neutral Good Pty LTD 4313, Shop 48 McAdams Square Croydon Hills, 3136 Australia RE: The tariff classification of “Prism” guided corporate exercises from China Dear Dr. Epstein: In your letter, dated August 12, 2025, you requested a tariff classification ruling on “Prism”, a set of printed paper cards used for guiding corporate exercises. Images and a description of the item were submitted for our review. The item under consideration is a boxed set of printed cards titled “Prism”. Regarding the use of “Prism”, you state: “The cards are used in structured facilitation exercises for strategy, leadership, and decision-making within organisations. Facilitators draw prompts from the deck to guide discussions, scenario analysis, and workshop activities. There is no randomisation mechanism beyond facilitator selection, and no win/lose objective.” “Prism” consists of approximately 600 lithographically printed cards and an instruction board that function as “a printed professional facilitation toolkit intended for use in corporate training, decision-making workshops, and consulting engagements. It is designed as a structured business tool and contains no competitive game rules, scoring, or elements of chance. The set is marketed exclusively for professional use and is not intended or designed for amusement.” In your letter, you suggest that “Prism” is classified in heading 4909, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Printed or illustrated postcards; printed cards bearing personal greetings, messages or announcements, whether or not illustrated, with or without envelopes or trimmings. The instant cards are not cards used for greeting or correspondence. Therefore, classification in heading 4911, HTSUS, is appropriate. The applicable subheading for “Prism” guided corporate exercises will be 4911.99.6000, HTSUS, which provides for “Other printed matter: Other: Other: Other: Printed on paper in whole or in part by a lithographic process.” The column one, general rate of duty will be Free. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. Merchandise classifiable under subheading 4911.99.6000, HTSUS, constitutes “any information or informational materials” encompassed by 50 U.S.C. § 1702(b)(3). Accordingly, such merchandise is exempt from additional duties under Executive Order 14195 pursuant to heading 9903.01.22, HTSUS. At the time of entry, you must report the applicable Chapter 99 heading, 9903.01.22, in addition to subheadings 4911.99.6000, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products from all other countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 subheading applicable to your product classification, 9903.01.31, in addition to subheading 4911.99.6000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4911.99.6000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, 9903.88.15, in addition to subheading 4911.99.6000, 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. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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. 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 Regulations (19 CFR 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, (for) Denise Faingar Acting Director National Commodity Specialist Division