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HQ 951626

October 8, 1992

CLA-2 CO:R:C:T 951626 JED


Tariff No.: 4802.52.1000

Mr. T.F. Burleigh
Vice President, Sales
Portals Inc.
500 Northridge, Suite 835
Atlanta, Georgia 30350

RE: Classification of cylinder mould paper, also known as, security paper

Dear Mr. Burleigh:

This is in reply to your letter of April 8, 1992, requesting that we review our position on the classification of security paper as set forth in Headquarters Ruling 087764 dated December 11, 1990.


The merchandise involved is a type of paper known as security paper. (The paper is also known as cylinder mould paper, a name derived from its production process.) In this particular instance, security paper is being imported for use as United States Postal Service Money Orders. A sample attached displayed a cylinder mould made watermark and a security thread.


What is the proper tariff classification of the above described security paper?


The General Rules of Interpretation (GRI's) taken in appropriate order provide a framework for classification of goods under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). The majority of imported goods are classified by application of GRI 1, that is according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes. Further, the Explanatory Notes (EN's) to the Harmonized Commodity Description and Coding System, which are the official interpretation of the tariff at the
international level, while not legally binding, facilitate classification under the HTSUSA by offering guidance in understanding the scope of the headings and GRI's.

Heading 4802, HTSUSA, provides for:

Uncoated paper and paperboard, of a kind used for writing, printing or other graphic purposes, and punch card stock and punch tape paper, in rolls or sheets, other than paper of heading 4801 or 4803; handmade paper and paperboard:

Analyzing the instant security paper based on the terms of the heading, the paper does not appear to have any coating. This comports with Chapter Note 2 to Chapter 48, HTSUSA, which states, in pertinent part, "[e]xcept where heading 4803 otherwise requires, these headings do not apply to paper, paperboard, cellulose wadding or webs of cellulose fibers which have been otherwise processed, for example, by coating or impregnation."

As to what is included within the scope of "writing paper", EN 48.02 (pg. 670) states, in pertinent part:

In addition to hand-made paper and paperboard and subject to Chapter Note 4 to this Chapter, the heading includes:

(B) Other paper and paperboard, of a kind used for writing, printing or other graphic purposes, for example:

(9) Security paper used for cheques, stamps, banknotes or the like.

Chapter Note 4 to Chapter 48, HTSUSA, states that, "[i]n addition to hand-made paper and paperboard, heading 4802 covers only paper and paperboard made mainly from bleached pulp or from pulp obtained by a mechanical process", and also lists sets of technical specifications applied to different weights of security paper.

As you note, Customs, in HQ 087764 (December 11, 1990), has previously classified security paper very similar to the instant paper in subheading 4802.52.1000. There, as here, Portals, Inc. proposed classification for the subject security paper in subheading 4802.52.9000, HTSUSA, as other uncoated paper.

The security paper in HQ 087764 was being imported for use as banknotes, travelers checks, vouchers, etc. This intended use was in accord with EN 48.02 (B)(9). Accordingly, Customs determined the security paper was properly classified in subheading 4802.52.1000, HTSUSA, provides for uncoated "writing paper."

In the instant case, we find that the intended use of the security paper as USPS Money Orders is a use like cheques, stamps and banknotes. Therefore, classification in subheading 4802.52.1000, HTSUSA, is proper.


Security paper such as the kind being imported for use as USPS Money Orders is properly considered "writing paper" as that term is used in Heading 4802, HTSUSA. Although you did not provide basis weight information on the paper, based on our experience with a similar paper, classification in subheading 4802.52.1000, HTSUSA, is correct.


John Durant, Director
Commercial Rulings Division

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