The tariff classification of paper labels from China and Vietnam

N359904 April 7, 2026 CLA-2-48:OT:RR:NC:N4:130 CATEGORY: Classification TARIFF NO.: 4821.10.2000 Schuyler Schouten Jones Day 4655 Executive Drive, Suite 500 San Diego, CA 92121 RE: The tariff classification of paper labels from China and Vietnam Dear Mr. Schouten: In your letter, dated March 20, 2026, you requested a tariff classification ruling. Detailed description, photos and a sample of the labels were submitted for our review. The merchandise under consideration is identified as “Gift Stickers” with Uniform Product Code (UPC) 843740144524. The item is a pack of eight sheets of adhesive stickers that are designed for attachment to gifts. Each sheet contains six stickers that are lithographically printed with Christmas- or holiday-themed designs or greetings accompanied with the words “To:” and “From:”, each followed by a space in which a name is to be entered by the user. You suggest the sticker sheets are classifiable in Chapter 49 of the Harmonized Tariff Schedule of the United States (HTSUS), we disagree. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level (for the four-digit headings and 6-digit subheadings) and facilitate classification under the Harmonized Tariff Schedule of the United States (HTSUS) by offering guidance in understanding the scope of the headings and the General Rules of Interpretation (GRIs). While neither legally binding nor dispositive of classification issues, the ENs provide commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of the headings. See T.D. 89-80. 54 Fed. Reg. 35127-28 (August 23, 1989). The ENs to heading 4821, HTSUS, state that: This heading covers all varieties of paper and paperboard labels of a kind used for attachment to any type of article for the purpose of indicating its nature, identity, ownership, destination, price, etc. They may be of the stick-on type (gummed or self-adhesive) or designed to be affixed by other means, e.g., string. These labels may be plain, printed to any extent with characters or pictures, gummed, fitted with ties, clasps, hooks or other fasteners or reinforced with metal or other materials. They may be perforated or put up in sheets or booklets. The instant gift stickers are used for attachment by adhesive to gifts and identify the giver and recipient of the gift. As such, we find that the instant stickers function as paper labels of heading 4821, HTSUS. The applicable subheading for the gift tag stickers will be 4821.10.2000, HTSUS, which provides for Paper and paperboard labels of all kinds, whether or not printed: Printed: Printed in whole or in part by a lithographic process. The general rate of duty will be free. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division