N364586

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 N364586 September 22, 2026 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification, Origin, Trade Programs TARIFF NO.: 3926.90.9989 Frederic Lapointe 3494250 Canada, Inc. / dba STiL Casing Solution 107 Quai Saint Andre Quebec City, QC G1K 3Y3 Canada RE: The tariff classification, country of origin, and eligibility for preferential treatment under the United States-Mexico-Canada Trade Agreement (USMCA) of archival preservation containers. Dear Mr. Lapointe: In your letter dated August 25, 2026, you requested a ruling regarding the tariff classification, country of origin, and eligibility for preferential treatment under the USMCA. Images were provided in lieu of samples. There are three products under consideration, and all are described as reusable archival preservation containers. The first, STiL 16mm Archival Film Preservation Containers STILAP16400, STiLAP16800, STiLAP161200, and STiLAP162000, are specifically designed for the long-term storage and preservation of 16-millimeter (mm) motion-picture films. Each container incorporates ventilation and airflow features designed to allow air circulation around, above, and below the stored film and to assist with long-term preservation. They will be imported empty and sold independently from the films they are designed to preserve. Further, while the containers are reusable, they are intended to remain with the film during long-term archival storage. The second, STiL 35mm Archival Film Preservation Containers STiLAP351000, STiLAP351200, STiLAP352000, STiLAP353000, and STILAP652000, are the same as the above products, except they are specifically designed for the long-term storage and preservation of 35mm motion-picture films. The third, STiL 1/4-Inch Magnetic Audiotape Archival Preservation Containers, are specifically designed for the long-term storage and preservation of 1/4-inch reel-to-reel magnetic audiotapes. These containers incorporate ventilation designed to assist with humidity stabilization and long-term preservation, as well as reel centering and storage stabilization features. They are designed specifically for archival storage rather than ordinary commercial packaging, and though reusable, they are intended to remain with the audiotapes during long-term archival storage. Models STIL-APA200C, STIL-APA270C, and STIL-APA305C differ primarily in dimensions and reel capacity but are otherwise identical. As these reusable archival preservation containers would 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/. Your submission states these three types of archival storage containers are injection molded, assembled, finished, inspected, and packaged in Canada. The polypropylene plastic resin used in the manufacturing process will be sourced from the United States. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. These preservation containers are neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of these articles, and paragraph (a)(3) must be applied next to determine the origin of the finished products. As indicated above, these containers are classified under heading 3926. The tariff shift requirement in part 102.20 for the articles of heading 3926 at issue states, “[a] change to heading 3922 through 3926 from any other subheading, including another heading within that group, except for a change to heading 3926 from articles of apparel and clothing accessories, other articles of plastics, or articles of other materials of headings 3901 to 3914 of heading 9619.” As the plastic resin, which is classified outside of heading 3926, is manufactured into the archival preservation containers in Canada, we find that it meets the required tariff shift, and therefore, in accordance with 19 CFR § 102.11(a)(3), the country of origin for these cases would be Canada. The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act. General Note (GN) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states, in relevant part: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if – (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); As the subject plastic preservation containers are produced entirely in Canada exclusively from United States sourced polypropylene plastic resin, they are considered originating under GN 11(b)(ii). Accordingly, the cases described above qualify for USMCA preferential tariff treatment. The merchandise will therefore be entitled to a free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and agreements. This ruling does not address the applicability of any additional duties, taxes, fees, exactions a

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 P. Forkan Director National Commodity Specialist Division