The tariff classification of a film cell wall display from the United Kingdom

N363784
August 5, 2026
CLA-2-37:OT:RR:NC:N3:135
CATEGORY: Classification
TARIFF NO.: 3706.10.6090
Paul Kerr 35mm Film Ltd 13 Sunnyside Road Alloa FK10 2AP United Kingdom RE: The tariff classification of a film cell wall display from the United Kingdom Dear Mr. Kerr: In your letter dated July 28, 2026, you requested a tariff classification ruling. The item under consideration, the “Authentic 35mm Cinema-Shown Film Cell Collectible Display,” is described as rare collectible cinema memorabilia and decorative wall art intended for home display and viewing. It consists of a plastic frame, a movie poster graphic for The Godfather, a Perspex cover, mountboard, a metal plaque bearing an individual serial or edition number, and a montage arrangement of twelve original, authentic 35mm cinematographic film cells surrounding the movie poster graphic. The film cells are cut from positive release prints of the feature film The Godfather. The product may also include an external, thin, low-voltage LED lightbox unit mounted on the back of the frame housing to illuminate the transparent film cells. You state that, if the LED lightbox unit is not selected, the display core is fitted with clear acrylic plastic (Perspex) sheets on both sides to protect the assembly while allowing natural ambient light to pass through the film cells. While we agree with you that the product should be classified according to the General Rules of Interpretation (GRI) 3(b) for composite goods, we disagree with your proposed classification under subheading 4911.91.4000, Harmonized Tariff Schedule of the United States (HTSUS). The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System. While not legally binding or dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. The General EN to Chapter 49, HTSUS, provides in pertinent part: “[T]his Chapter covers all printed matter of which the essential nature and use is determined by the fact of its being printed with motifs, characters or pictorial representations.” In the instant product, the movie poster graphic does not impart the essential character of the product. Rather, based on the quantity and value of the 35mm film cells, as well as their role in relation to the use of the product, they impart the essential character of the collectible cinema

memorabilia and decorative wall art display. Note 1(a) to Chapter 49 states that this chapter does not cover photographic negatives or positives on transparent bases. Therefore, classification under subheading 4911.91.4000, HTSUS, is precluded. The applicable subheading for the “Authentic 35mm Cinema-Shown Film Cell Collectible Display” will be 3706.10.6090, HTSUS, which provides for “Motion-picture film, exposed and developed, whether or not incorporating sound track or consisting only of soundtrack: Of a width of 35mm or more: 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 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 Fei Chen at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division