The tariff classification of a Fiber Packaging System from Canada

N361911June 9, 2026CLA-2-84:OT:RR:NC:N1:118
CATEGORY: Classification
TARIFF NO.: 8441.40.0000
Patricia CerisanoGranite Professional Services20 Previn CourtAlliston, ON L9R 1N8CanadaRE: The tariff classification of a Fiber Packaging System from CanadaDear Ms. Cerisano:In your letter dated
May 29, 2026
, you requested a tariff classification ruling on behalf of your client, AviridiInc.The merchandise under consideration is identified as a CIMA Pulpformer™ 1200 Duo Molded Fiberan industrial production line designed and engineeredPackaging System (the “CIMA Pulpformer™”). It is for the manufacture of molded fiber packaging articles from prepared pulp slurry composed primarily ofcellulosic fiber materials.The system manufactures molded fiber packaging products trays, ,such ascontainers, clamshell packaging, and protective packaging articles.You have stated that the system is specifically designed and dedicated for molded fiber article production and is not capable of processingplastics or rubber materials.The production process consists generally of the following stages: 1) Fiber forming onto forming molds tocreate the initial molded article; 2) Pressing operations to remove moisture and stabilize the molded article;3) Integrated drying operations; 4) Trimming and finishing operations; and 5) Automated stacking ofcompleted molded fiber articles.The system consists primarily of structural steel assemblies, stainless steel process components, hydraulicsystems, vacuum systems, motors, conveyors, electrical control systems, and integrated automationcomponents.The imported system includes the following principal modules and components: Vacuum Pump ModuleForming PressWet GantryDrying Module
Hydraulic Power Pack ModuleDry GantryTrim PressStackerConveyorsGuarding and Safety FencingElectrical Control CabinetWiring Harnesses and Integrated Electrical ComponentsYou have stated that due to transportation and handling requirements, the system will be imported in anunassembled/disassembled condition across multiple truckloads. However, you attest that the completesystem will be imported under a single customs entry. Please note that merchandise is to be classifiedaccording to its condition as imported. Should the requirements of 19 CFR § 141.51 and 19 CFR § 141.58not be met, each component of the system would be separately classified in its own respective heading.Note 4 to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS), describes afunctional unit as a machine or combination of machines consisting of individual components (whetherseparate or interconnected by piping, transmission devices, electric cables or by other devices) intended tocontribute together to a clearly defined function covered by one of the headings in chapter 84 or chapter 85.The whole then falls to be classified in the heading appropriate to that function. The CIMA Pulpformer™meets this description, with the clearly defined function of molded fiber packaging manufacturing (e.g., trays,containers, clamshell packaging, and protective packaging articles).The applicable subheading for the will beCIMA Pulpformer™ 1200 Duo Molded Fiber Packaging System8441.40.0000, HTSUS, which provides for other machinery for making up paper pulp, paper or paperboard,including cutting machines of all kinds, and parts thereof: machines for molding articles in paper pulp, paperor paperboard.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 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 the classification 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 Anthony Grossi at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division