RE: The tariff classification of printed wall art from Poland

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 N363761 August 24, 2026 CLA-2-49:OT:RR:NC:N4:434 CATEGORY: Classification TARIFF NO.: 4911.91.4040; 4911.99.8000 Bartosz Rodak GWD Concept Spolka z ograniczona odpowiedzialnoscia Al. Jerozolimskie 123A Warszawa 02-017 Poland RE: The tariff classification of printed wall art from Poland Dear Mr. Rodak: In your letter dated July 27, 2026, you requested a tariff classification ruling on printed metal posters for prospective shipments. Three samples and product information were submitted for our review. This ruling will be based on the samples received. The items under consideration are three styles of wall art identified as “Displate Metal Posters.” These wall arts are UV inkjet-printed on flat, zinc-coated (galvanized) steel sheets. They are available in three sizes: medium (320 mm x 450 mm), large (480 mm x 675 mm) and extra-large (640 mm x 900 mm). The extra-large poster consists of four separate medium sized posters. The first item, design number 5852289_1002_MATTE, “Bonfire in the Shrine,” portrays an armored knight standing before a bonfire and is entirely pictorial. The second item, design number 7956481_1001_TEXTRA, “Paul Atreides: Golden Dune Messiah,” features a man wearing a cloak and mask wielding a dagger; it is also entirely pictorial. The third item, design number 6179483_1001_MATTE, “World Map Text Art,” is a typographic representation of a world map, with country names forming the shapes of the continents and landmasses; it consists entirely of text. You indicate that each “Displate Metal Poster” includes a magnetic wall-mounting kit consisting of an adhesive protective leaf and a magnet; however, the kit is invoiced separately and is not considered in this ruling request. In your ruling request, you noted that in ruling letter N362474, our office classified “Displate Metal Posters” with pictorial designs under subheading 4911.91.4040, Harmonized Tariff Schedule of the United States (HTSUS), and designs that are predominantly text-based under 4911.99.8000, HTSUS. You indicate that you are seeking a ruling that would apply to your entire product line of Displate Metal Posters comprised of approximately 2.5 million different designs.
You proposed to classify the entire product line under subheading, 4911.91.4040, HTSUS, arguing that determining a distinct subheading for each individual design at the time of entry is administratively impracticable and that a single classification for the entire product line promotes consistency and supports the exercise of reasonable care. We disagree. Classification is based on the facts of the specific item at the time of importation. Each individual item must be evaluated based on its own physical characteristics, composition, and function. If items within a product line possess distinct characteristics, such as one being primarily pictorial and another being primarily text-based, they must be classified according to those facts. A ruling letter addresses a specific set of facts. See 19 CFR 177.1(d)(1). For this reason, we do not issue “blanket” rulings or rulings on lines of merchandise. The importer of record is responsible for using reasonable care to enter, classify and determine the value of imported merchandise and to provide any other information necessary to enable the U.S. Customs and Border Protection to properly assess duties, collect accurate statistics, and determine whether other applicable legal requirements, if any, have been met. However, it would not be improper in the exercise of reasonable care to cite to a ruling decision (e.g., N362474) issued for a particular product in support of the classification of another product that is substantively identical (e.g., Displate Posters with designs that are primarily pictorial under subheading 4911.91.4040, HTSUS, versus Displate Posters with designs that are primarily text-based under subheading 4911.99.8000, HTSUS). The applicable subheading for design number 5852289_1002_MATTE, “Bonfire in the Shrine,” and design number 7956481_1001_TEXTRA, “Paul Atreides: Golden Dune Messiah,” will be 4911.91.4040, HTSUS, which provides for Other printed matter, including printed pictures and photographs: Other: Pictures, designs and photographs: Printed not over 20 years at time of importation: Other: Other: Other. The general rate of duty will be free. The applicable subheading for design number 6179483_1001_MATTE, “World Map Text Art,” will be 4911.99.8000, HTSUS, which provides for Other printed matter, including printed pictures and photographs: Other: Other: Other: Other. 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 provided at https://hts.usitc.gov/. This ruling is issued for prospective shipments only and 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 Susana Li at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division