RE: The tariff classification, country of origin, and application of trade agreements for paper artwork

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 N365695 October 19, 2026 CLA-2-44:OT:RR:NC:N5:130 CATEGORY: Classification; Origin; Trade Programs TARIFF NO.: 4823.90.8680; 4602.90.0000 Ms. Maryam Shafaei Topology Studio 198 Northwood Drive Toronto, ON M2M 2K4 Canada RE: The tariff classification, country of origin, and application of trade agreements for paper artwork Dear Ms. Shafaei: In your letter, dated October 2, 2026, you requested a binding classification, country of origin, and application of trade programs ruling on paper artwork. Information and photos were submitted for our review. You have submitted two pieces of artwork for our review. The first is artwork constructed of folded pieces of uncoated paper presented in a three-dimensional format. The folded pieces of paper are cut, folded, and glued to a rigid plastic backing. The second is artwork constructed of multiple varieties of paper strips that are interwoven into sheets, cut to shape, and combined by stacking and adhering. The interwoven strips are not mounted on any kind of backing. The applicable subheading of the folded paper artwork will be 4823.90.8680, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other paper, paperboard, cellulose wadding and webs of cellulose fibers, cut to size or shape; other articles of paper pulp, paper, paperboard, cellulose wadding or webs of cellulose fibers: Other: Other: Other: Other: Other: Other. The general rate of duty will be free. Note 1 to Chapter 46, HTSUS, identifies strips of paper as plaiting materials: In this chapter the expression "plaiting materials" means materials in a state or form suitable for plaiting, interlacing or similar processes; it includes straw, osier or willow, bamboos, rattans, rushes, reeds, strips of wood, strips of other vegetable material (for example, strips of bark, narrow leaves and raffia or other strips obtained from broad leaves), unspun natural textile fibers, monofilament and strip and the like of plastics and strips of paper, but not strips of leather or composition leather or of felt or nonwovens, human hair, horsehair, textile rovings or yarns, or monofilament and strip and the like of chapter 54. The finished woven artwork is an article of plaiting material. The applicable subheading for the interwoven paper strip artwork will be 4602.90.0000, HTSUS, which provides for Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601; articles of loofah: Other. The general rate of duty will be 3.5 percent ad valorem. For the folded artwork, you outline a scenario wherein Chinese paper is cut, folded, shaped, arranged, and adhered to a Chinese plastic backing in Canada. The adhesive is also of Chinese origin. For the interwoven artwork, Chinese paper is cut into strips, interwoven, cut to shape, and adhered in Canada. The United States-Mexico-Canada Agreement (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— the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; 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)); Neither piece of artwork is wholly obtained or produced in one or more USMCA country. Therefore, we proceed to subdivision (o). For the folded art classifiable in heading 4823, Subdivision (o) states that, in order to be subject to USMCA, the manufacturing in a USMCA country must result in “A change to any other good of heading 4823 from strip or rolls of a width exceeding 15 cm of heading 4823, other than strips or rolls of heading 4823 which but for their width would be classified in headings 4803, 4809 or 4814, floor coverings on a base of paper or paperboard of heading 4823, from or any other heading, except from strip or rolls of a width exceeding 15 cm but not exceeding 36 cm or paper or paperboard in rectangular (including square) sheets with one side not exceeding 15 cm in the unfolded state of headings 4802, 4810 or 4811, or from headings 4817 through 4822.” The paper, likely of heading 4802, presented in 8.5-inch by 11-inch sheets, is cut and folded to become an article of 4823. Since the change occurs from 4802 to 4823, the rule is met. Therefore, the folded artwork qualifies for USMCA preferential treatment. For the interwoven art classifiable in heading 4602, Subdivision (o) states that, in order to be subject to USMCA, the manufacturing in a USMCA country must result in “A change to heading 4602 from any other heading.” The paper, classified in Chapter 48, is cut, interwoven, and adhered to become an article of heading 4602. The rule is met by this manufacturing. Therefore, the interwoven paper art qualifies for USMCA preferential treatment. The country of origin for duty purposes is Canada. Both products are unconditionally free of duty under the USMCA. The "country of origin" is defined in Title 19, Code of Federal Regulations (CFR), Section 134.1(b) 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 this part; however, for a good of a NAFTA or USMCA country, the marking rules set forth in part 102 of this chapter (hereinafter referred to as the part 102 Rules) will determine the country of origin. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in §§ 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile goods which are subject to the provisions of 19 C.F.R. § 102.21. See 19 C.F.R. § 102.11. 19 CFR Part 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. The artworks are neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of the artworks and paragraph (a)(3) must be applied next to determine the origin of the finished article. Section 102.20 (19 CFR 102.20) sets forth the applicable tariff change rules that address the current scenario. Goods classified in heading 4823 must undergo a change as follows: “A change to any other good of subheading 4823.90 from floor covering on base paper or of paperboard, self-adhesive paper, other gummed or adhesive paper, or from cards not punched and for punchcard machines of subheading 4823.90, or from any other subheading.” Additionally, Goods classified in heading 4602 must undergo a change as follows: “A change to heading 4602 from any other heading.” The paper and other materials from China undergo the noted changes. Therefore, the artworks are of Canadian origin for marking purposes. The pieces can be marked “Made in Canada” or “Product of Canada” as appropriate. 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