May 9 CBP Bulletin Proposes to Modify or Revoke Rulings on Printer Media Rolls, Floppets
In the May 9 Customs Bulletin (Vol. 52, No. 19), CBP published notices that propose to modify or revoke rulings and similar treatment for media rolls on plastic reels for printers and for floppets.
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Comments on Proposals Due June 8
CBP said consideration will be given to any written comments received by June 8 before taking this action. In addition, any party who has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Media Rolls for Printers
| Item: DK self-adhesive labels and the continuous length tapes imported on plastic reels which are designed for use with Brother QL Series Label Printers. Each QL printer is intended to work with specific DK media rolls. A code aperture on each roll allows the printer to distinguish which particular DK media roll is in the printer. This lets the printer know which model DK media roll is in the machine to inform the print area for the specific DK tape that has been inserted. |
| Current: As self-adhesive plastics and paper of headings 3919, 4811, and 4821. |
| Proposed: 8443.99.25, free, “Printing machinery ... other printers ... : parts and accessories: other: parts and accessories of printers: other.” |
| Reason: The code apertures on the rolls means they are not mere rolls of plastic or paper. The rolls are instead “parts” of printers because they are integral to, and dedicated solely for use with, the Brother QL Series Label Printer, without which the printer machines could not function. |
| Proposed for revocation: NY N246471 (2013) |
| Proposed new ruling: HQ H251008 |
Floppets
| Item: Floppets are polyvinyl chloride (PVC) character charms on a hook and loop strip. These charms are available in such forms as hamsters, octopuses and penguins. The loop allows the floppet to be used on the finger, back pack, flip flops, shoe laces, wrists or ankles. |
| Current: 3926.40.00, 5.3%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Statuettes and other ornamental articles.” |
| Proposed: 7117.90.75, free, "Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Of plastics.” |
| Reason: Floppets are made of a textile strap and a plastic figure, so heading 3926 describes only part of the good. Floppets can be worn like rings, pendants from a necklace or charms from a bracelet, or they can attach through buttonholes near a shirt collar like a brooch, on belts like a buckle, or on handbags. They are described by the definition of imitation jewelry in Note 11 to Chapter 71. |
| Proposed for revocation: NY N241384 (2013) |
| Proposed new ruling: HQ H249749 |