Unprinted Paper & Paperboard Labels of All Kinds

Technical data sheets confirming the presence of a pressure-sensitive adhesive layer, along with commercial invoices that explicitly describe the labels as self-adhesive or pressure-sensitive, are the most effective supporting documents. Physical samples may also be requested by CBP during examination to verify the adhesive characteristic.

No. The classification of unprinted paper labels under heading 4821.90 is determined by the adhesive type, not the physical form (sheet, roll, or fanfold). Labels in roll form that are pressure-sensitive still enter under 4821902000; non-pressure-sensitive roll labels enter under 4821904000. However, if the rolls are more accurately described as label stock or base paper rather than finished labels, classification in Chapter 48 as paper in rolls may be more appropriate.