Classification of cylinder mould paper, also known as, security paper
Active· CBP ruling HQ 951626· Issued 1992-10-08
Ruling text
HQ 951626
October 8, 1992
CLA-2 CO:R:C:T 951626 JED
Category: Classification
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.
FACTS:
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.
ISSUE:
What is the proper tariff classification of the above
described security paper?
LAW AND ANALYSIS:
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
-2-
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.
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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.
HOLDING:
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.
Sincerely,
John Durant, Director
Commercial Rulings Division
Source: rulings.cbp.gov — ruling 951626, retrieved 2026-10-12T05:26:33Z, republished verbatim. This digest is informational; only CBP issues binding rulings.