The tariff classification of wall display signs and product display signs from Canada

N360783May 12, 2026CLA-2-49:OT:RR:NC:N4:434
CATEGORY: Classification
TARIFF NO.: 4911.10.0080; 9610.00.0000
Jillian YewellLush Cosmetics, Ltd.8680 Cambie Street, 307Vancouver V6P 6M9CanadaRE: The tariff classification of wall display signs and product display signs from CanadaDear Ms. Yewell:In your letter dated
April 16, 2026
, you requested a ruling concerning the tariff classification of wall displaysigns and product signs. Representative photos and product descriptions were provided for our review.The first product under consideration is the Lush Cosmetics Wall Display Signage. The signs are constructedof a ½-inch-thick plywood sheet that will be cut to size based on retail location needs, in dimensions such as36 inches by 28 inches, 23 inches by 84 inches, etc. The boards will be painted with black primer paint, andhandwritten with the product category name, display slogans, or general advertising using white poster pens(not included) to achieve chalkboard style writing consistent with Lush Cosmetics retail location wall signs. A French cleat is installed on the backside of the sign to secure it to a wall for visual display purposes. Peryour correspondence, the wall signs will either be handwritten in Canada prior to importation into the U.S. orhandwritten in the U.S. after importation. The second product is the Lush Cosmetics Product Signage. The signs are constructed of 100% blackpolypropylene plastic.The front of the sign is digitally printed in a chalkboard-style font with product name, usage, and a blank space for handwriting a retail price.The back of the sign is printed with product ingredients. The product signs are designed to be placed in the bowls with the products, near the product on astand, or attached to a product display with double-sided Velcro tape.For both the Lush Cosmetics Wall Display Signage and the Lush Cosmetics Product Signage, you proposeclassification in subheading 9610.00.0000, Harmonized Tariff Schedule of the United States (HTSUS),which provides for slates and boards with writing or drawing surfaces. The Explanatory Notes (EN’s) to heading 9610 describe the slates and boards appropriate for classification inthis heading as being clearly designed to be used for writing or drawing with slate pencils, chalks, felt or fibre
tipped markers (e.g., school children’s slates, blackboards and certain notice boards). This describes theinstant wall display signs when imported blank. Printed signs or signs handwritten prior to importationcannot be classified in this heading unless they contain significant open surface for writing or drawing. Therefore, the handwritten wall signs and the printed product signs are precluded from display classificationsubheading 9610.00.0000, HTSUS. in The first paragraph of the General Explanatory Notes to Chapter 49, HTSUS, states: “With the fewexceptions referred to below, this Chapter covers all printed matter of which the essential nature and use isdetermined by the fact of its being printed with motifs, characters or pictorial representations.” The GeneralENs to Chapter 49 further clarify: “In general the goods of this Chapter are executed on paper but the goodsmay be on other materials provided they have the characteristics described in the first paragraph of thisGeneral Explanatory Note.” These provisions describe the instant products: the handwritten plywood wall signage and the printed polypropylene product signage.The essential nature and use of these signs are determined by the fact that they are handwritten or printed with text, such as the company’s slogan, productcategory names, and product information.It is the handwritten and printed text that enables them to function as display signs in stores. The applicable subheading for the handwritten Lush Cosmetics Wall Display Signage and the printed LushCosmetics Product Signage will be 4911.10.0080, HTSUS, which provides for Other printed matter,including printed pictures and photographs: Trade advertising material, commercial catalogs and the like:Other. The general rate of duty will be free.The applicable subheading for the Lush Cosmetics Wall Display Signage, if imported blank, will be9610.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Slates andboards, with writing or drawing surfaces, whether or not framed. The general rate of duty will be 3.5 percentad valorem.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Susana Li at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division