RE: The tariff classification of a paperboard keepsake box from China

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 N364323 August 24, 2026 CLA-2-48:OT:RR:NC:N5:130 CATEGORY: Classification TARIFF NO.: 4819.50.4040 Ms. Donna Huggins Franco Manufacturing Co. Inc. 555 Prospect Street Metuchen, NJ 08840 RE: The tariff classification of a paperboard keepsake box from China Dear Ms. Huggins: In your letter, dated August 12, 2026, you requested a binding tariff classification ruling on a paperboard keepsake box. Product information and a sample were submitted for our review. The product under consideration is a paperboard keepsake box. The box is constructed of rigid paperboard that is covered with high gloss paper. The sample box is unprinted, but the images provided indicate that the box will be printed on the inside and out to coordinate with the contents. The box measures 13.5 inches long by 10 inches wide by 4.75 inches high and will be imported containing a blanket and a children’s book. The box has a hinged lid and a slot cut in the lid and side, which appear to be intended to allow a ribbon to be inserted to tie the box shut. The box, although, constructed of paperboard, is substantial and suitable for repetitive use after importation. The submitted sample also includes a paperboard belly band which indicates the title of the book and identifies the contents of the box. The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of products or articles put together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).” The blanket, book, and keepsake box do not constitute “goods put up in sets for retail sale” as the articles do not together meet a particular need or carry out a specific activity. Therefore, upon importation, the three components must be entered separately. We will only address the classification of the paperboard box in this ruling. Insufficient information was provided to classify the blanket and book. General Rule of Interpretation 5(b), HTSUS, governs the classification of packaging materials:
Subject to the provisions of rule 5(a) above, packing materials and packing containers entered with the goods therein shall be classified with the goods if they are of a kind normally used for packing such goods. However, this provision is not binding when such packing materials or packing containers are clearly suitable for repetitive use. The keepsake box is suitable for repetitive use and, therefore, will be classified separately from the blanket and book. The belly band, on the other hand, is normal packing material that will be classifiable with the contents of the box. The belly band need not be separately entered. The applicable subheading for the paperboard keepsake box (without the blanket and book) will be 4819.50.4040, HTSUS, which provides for Cartons, boxes, cases, bags and other packing containers, of paper, paperboard, cellulose wadding or webs of cellulose fibers; box files, letter trays and similar articles, of paper or paperboard of a kind used in offices, shops or the like: Other packing containers, including record sleeves: Other: Other: Rigid boxes and cartons. The general rate of duty will be free. 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 Laurel Duvall at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division