N359104

N359104 March 19, 2026 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 3926.90.9989 Andrew Clifforth Essential Film Holder 1 Beestom Close, Highwood Gardens Tiverton, EX16 4FY United Kingdom RE: The tariff classification of a plastic film holding device and components from the United Kingdom. Dear Mr. Clifforth: In your letter dated February 23, 2026, you requested a tariff classification ruling. Images were provided in lieu of samples. This request consists of three products. The first is described as the Essential Film Holder (EFH), which is a device designed solely to position and hold photographic film (35mm and 120mm formats) flat and aligned during digital photographic reproduction (camera scanning/digitization) using an external light source (e.g., LED panel or tablet) and a digital camera positioned above. The holder is primarily made of acrylic plastic including the structural components, and the parts (posts, spacers, lock nuts, wing nuts, and non-slip feet) are made of nylon plastic. Your submission indicates this article contains no metal, glass, optical elements, electronic components, integrated lighting, nor image capture capability. The second is described as interchangeable masks which are used as part of a system comprising the first item. The third is described as replacement mask layers which are used as part of a system comprising the two above items. In your submission you suggest that the EFH is classifiable as “parts and accessories” in subheading 9006.99 or 9010.90. The eight-digit classifications you provided do not exist in the tariff; however, for the purposes of this paragraph your suggestions to the six-digit level are sufficient. In each of the provisions you have provided, your contention is that the EFH would be classified as a part or accessory of photographic cameras, and photographic flashlight apparatus and flashbulbs or, alternatively, as a part of accessory of apparatus and equipment for photographic (including cinematographic) laboratories, negatoscopes, or projection screens. We disagree with your proposed conclusions. The EFH is said to be designed solely to position and hold photographic film flat and aligned during digital photographic reproduction using a separate external light source and a separate digital camera positioned above it. We maintain that the EFH is not a part of any of the above-mentioned headings, it is not integral to the function of any of the equipment covered by the suggested subheadings nor is it specifically designed to fit or adapt to any single piece of such equipment. Furthermore, we hold the opinion that the EFH is not an accessory of any of the above-mentioned headings. It does not directly relate or bear a direct relationship to the primary article that it would accessorize. For example, the EFH does not directly affect (i.e., enhance) the operation of any of the articles provided for in the suggested subheadings. See HQ ruling number H308383, dated October 28, 2020. As the Essential Film Holder, interchangeable masks, and replacement mask layers would all be considered articles of plastic, and as they are not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem. 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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

device and components from the United Kingdom. Dear Mr. Clifforth: In your letter dated February 23, 2026, you requested a tariff classification ruling. Images were provided in lieu of samples. This request consists of three products. The first is described as the Essential Film Holder (EFH), which is a device designed solely to position and hold photographic film (35mm and 120mm formats) flat and aligned during digital photographic reproduction (camera scanning/digitization) using an external light source (e.g., LED panel or tablet) and a digital camera positioned above. The holder is primarily made of acrylic plastic including the structural components, and the parts (posts, spacers, lock nuts, wing nuts, and non-slip feet) are made of nylon plastic. Your submission indicates this article contains no metal, glass, optical elements, electronic components, integrated lighting, nor image capture capability. The second is described as interchangeable masks which are used as part of a system comprising the first item. The third is described as replacement mask layers which are used as part of a system comprising the two above items. In your submission you suggest that the EFH is classifiable as “parts and accessories” in subheading 9006.99 or 9010.90. The eight-digit classifications you provided do not exist in the tariff; however, for the purposes of this paragraph your suggestions to the six-digit level are sufficient. In each of the provisions you have provided, your contention is that the EFH would be classified as a part or accessory of photographic cameras, and photographic flashlight apparatus and flashbulbs or, alternatively, as a part of accessory of apparatus and equipment for photographic (including cinematographic) laboratories, negatoscopes, or projection screens. 

We disagree with your proposed conclusions. The EFH is said to be designed solely to position and hold photographic film flat and aligned during digital photographic reproduction using a separa