The tariff classification and eligibility of the United States-Mexico-Canada Agreement (USMCA) of PVC wall decals from Canada

N353565 September 30, 2025 CLA-2-39:OT:RR:NC:N5: 137 CATEGORY: Classification, Trade Programs TARIFF NO.: 3919.90.5060, 9903.01.14 Lindsay Smith Wall Candy Design Co. 151 Hillview Lane Strathmore T1P 1Z8 Canada RE: The tariff classification and eligibility of the United States-Mexico-Canada Agreement (USMCA) of PVC wall decals from Canada Dear Ms. Smith: In your letter dated September 10, 2025, you requested a binding ruling on the tariff classification and eligibility of PVC wall decals under the United States-Mexico-Canada Agreement (USMCA). The products under review are removable wall decals comprised of polyvinyl chloride (PVC) sheets backed with transfer tape. The decals are imported in sheets packaged and ready for retail sale. The decals are not printed but are plotted and cut into the vinyl. The designs are decorative and may incorporate repetitive patterns depending on the design and package size. Rolls of U.S. origin PVC and transfer tape are sourced from a supplier in Canada. The following steps take place in Canada: Custom designs are created digitally. Vinyl is loaded into a plotter and cut to shape Transfer tape is manually applied over the design. Decals are cut into individual sheets. Finished decals are bagged with insert cards and instructions. Classification: The applicable subheading for the PVC wall decals will be 3919.90.5060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for self-adhesive plates, sheets, film, foil, strip and other flat shapes, of plastics: whether or not in rolls: other: other: other. The general rate of duty will be 5.8 percent ad valorem. Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to subheading 3919.90.5060, HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to subheading 3919.90.5060, HTSUS. USMCA: The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN") 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a "good originating in the territory of a USMCA country" only if- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since all of the ingredients in the PVC wall decals are USMCA originating, the product is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials under GN 11(b)(ii). Therefore, the PVC wall decals would be eligible for preferential tariff treatment under the USMCA. 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 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division