RE: The tariff classification and country of origin of stencil plates

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365625 October 15, 2026 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification; Origin TARIFF NO.: 7326.90.8688 Julian McKechnie Gistar UK 57 Woods Avenue, Marsden Huddersfield HD7 6JY United Kingdom RE: The tariff classification and country of origin of stencil plates Dear Mr. McKechnie: In your letter dated October 1, 2026, you requested a tariff classification and country of origin determination ruling. Informational material was submitted with your request. The products under consideration are stencil plates identified as the “Metal Guitar Chord Stencil.” The plates are made of 0.3 millimeter (mm) thick stainless steel, rectangular in shape, and measures 84 mm in length and 55 mm in width. Each stencil includes three sets of vertical straight slits that are meant to resemble the fretboards of three different stringed instruments: guitar, banjo, and ukulele. The slits allow users to draw straight lines for each designated instrument so they can transcribe string chords for composing music. In the final product, an image of each instrument is printed next to the set of slits it represents. There are 6 slits on the upper left half of the plate representing the guitar, 5 slits in the middle on the lower half representing the banjo, and 4 slits on the upper right half representing the ukulele. The stencil is available in three colors, blue, red, or clear. The manufacturing process for these stencil plates begins in China. In this country the overall shape of the plates is cut from stainless steel sheets. Once the plates are cut, they undergo further processing where the corners are rounded, and slits representing the fretboards are cut into the plate. The plates are then shipped to the United Kingdom (UK) where the images of the instruments are printed onto them, undergo final inspection, and finally packed and shipped to the United States. In your submission, you suggest the stencil plates should be classified under heading 7326, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of iron or steel.” We agree. Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7326 state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel can be classified in heading 7326 if it is determined that the item is not more specifically provided for in any other heading of the tariff. The stencil plates are not specifically covered elsewhere in the tariff. Accordingly, it is classifiable in heading 7326, HTSUS. The applicable subheading for the stencil plates will be 7326.90.8688, HTSUS, which provides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9 percent ad valorem. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In your submission you also suggest the country of origin for the stencil plates should be declared and marked as made in the UK. We disagree. Although the plates are semifinished and undergo processes in the UK, the plates and slits are already formed and cut into their finished shape and size before they leave China. In this sense, the final product, a stencil plate, achieves its name, character, and use as a stencil plate in China. The printing process performed in the UK does not constitute substantial transformation because the plates would retain the name, character, and use they received from the manufacturing process in China. Accordingly, the country of origin of the stencil plates are China and should marked as such in accordance with Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304). 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 Matthew Gay at matthew.gay@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division