United States International Trade Commision Rulings And Harmonized Tariff Schedule
faqs.org  Rulings By Number  Rulings By Category  Tariff Numbers
faqs.org > Rulings and Tariffs Home > Rulings By Number > 1994 HQ Rulings > HQ 0956637 - HQ 0956873 > HQ 0956754

Previous Ruling Next Ruling

HQ 956754

August 9, 1994

CLA-2 CO:R:C:T 956754 ch


TARIFF NO.: 4820.10.2020

Thomas E. Bernstein
Vice President
4431 William Penn Highway
Murrysville, Pennsylvania 15668

RE: Classification of stationery article from China; memorandum pad.

Dear Mr. Bernstein:

This is in response to your letter of May 17, 1994, requesting tariff classification under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) for the "Ballastic Canvas Writing Pad." A sample was provided to this office for examination.


The submitted sample, style 0800-01, is described as the "Ballastic Canvas Writing Pad." Style 0800-01 consists of a woven polyester textile folder measuring approximately 10 inches by 13 1/2 inches, and a lined paper writing tablet which is inserted into a slot on the inside of the folder. The interior of the folder also possesses a pen holder, as well as open flat pockets designed to hold business cards, computer disks and loose papers. The exterior features an open full wall pocket.


What is the proper tariff classification for the "Ballastic Canvas Writing Pad?"


Heading 4820, HTSUSA, provides in part for memorandum pads and other articles of stationery, of paper or paperboard. The Explanatory Note (EN) to heading 4820 states in pertinent part, at page 687, that:

This heading covers various articles of stationery, other than correspondence goods of heading 4817 and the goods referred to in Note 9 to this Chapter. It includes:

(1) Registers, account books, note books of all kinds, order books, receipt books, copy books, diaries, letter pads, memorandum pads, engagement books, address books and books, pads, etc. for entering telephone numbers.

(3) Binders designed for holding loose sheets, magazines, or the like (e.g. clip binders, spring binders, screw binders, ring binders), and folders, file covers, (other than box files) and portfolios.

(8) Book covers (binding covers and dust covers), whether or not printed with characters
(title, etc.) or illustrations.

The goods of this heading may be bound with materials other than paper (e.g. leather, plastics or textile material) and have reinforcements or fittings of metal, plastics, etc. (Emphasis added).

This language indicates that articles of 4820, HTSUSA, include memorandum pads, folders and book covers. In addition, articles of heading 4820 may be bound with leather, plastics or textile material.

In Headquarters Ruling Letter (HRL) 951076, dated March 18, 1992, issued to Leeds Leather Products, we classified the "President Writing Pad," which was described as follows:

The second item, "President Writing Pad," is a 9 1/2 by 12 1/2 inch leather folder containing an 8 1/2 by 11 inch pad of lined writing paper. The cardboard backing sheet of the pad is slipped into a large pocket inside the leather folder, which also incorporates a pen holder and an additional pocket for loose papers.

In that decision, we noted that memorandum pads were classifiable in heading 4820, HTSUSA. Citing lexicographic sources, we concluded that a memorandum pad is "an article featuring a block of blank pages attached at one end to facilitate note taking." The paper writing pad met the description of a memorandum pad. Moreover, we determined that the leather folder merely emphasized the primary purpose of the article, which was to provide a convenient and organized method to take notes. Accordingly, the "President Writing Pad" was classifiable as a memorandum pad of subheading 4820.10.2020, HTSUSA.

Style 0800-01 is substantially similar in design and function to the "President's Writing Pad." The textile jacket functions as a cover for the memorandum pad and as an organizational aid for note taking. Consequently, the article is classifiable as a memorandum pad of subheading 4820.10.2020, HTSUSA.


The subject merchandise is classifiable under subheading 4820.10.2020, HTSUSA, which provides for memorandum pads, letter pads and similar articles. The applicable rate of duty is 4 percent ad valorem.


John Durant, Director

Previous Ruling Next Ruling

See also: