The General Rules of Interpretation ("GRIs") and the ARIs govern classification of merchandise under the HTSUS, and are applied in numerical order. N. Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed. Cir. 2001). When determining the correct classification for merchandise, a court first construes the language of the headings in question, in light of any related section or chapter notes.

The General Rules of Interpretation ("GRIs") govern classification of merchandise under the HTSUS. N. Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed. Cir. 2001). Under GRI 1, the court must determine the appropriate classification "according to the terms of the headings and any relative section or chapter notes."

Customs complied with its regulations and gave notice to Jewelpak, as the `person to whom the ruling letters [were] addressed,' that Customs was considering revocation of the HRLs. This case is simply a revocation of an HRL by Customs."). And, despite Jewelpak's protestation, the law is clear that it was wholly appropriate to reference the Amended Explanatory Note (which, in this case, contained the "long-term use" limitation) to help define the proper scope of the tariff term. See, e.g., Mita Copystar Am. v. United States, 21 F.3d 1079, 1082 (Fed. Cir. 1994) ("[T]he Explanatory Notes of a tariff subheading . . . do not constitute controlling legislative history but nonetheless are intended to clarify the scope of HTSUS subheadings and to offer guidance in interpreting subheadings."); accord N. Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed. Cir. 2001); Carl Zeiss, Inc. v. United States, 195 F.3d 1375, 1378 n. 1 (Fed. Cir. 1999). Jewelpak's claim that Customs violated 19 C.F.R. § 177.10 also fails because it cannot demonstrate that it was subject to a restriction or prohibition.

Mead Corp. v. United States, 283 F.3d 1342, 1345 (Fed. Cir. Mar. 8, 2002). The proper scope and meaning of a tariff classification term is a question of law to be reviewed de novo, Rollerblade, Inc. v. United States, 112 F.3d 481, 483 (Fed. Cir. 1997), while determining whether the goods at issue fall within a particular tariff term as properly construed is a question of fact, N. Am. Processing Co. v. United States, 236 F.3d 695, 697 (Fed. Cir. 2001). We afford Customs' classification rulings deference in accordance with the principles set forth in Skidmore v. Swift Co., 323 U.S. 134, 65 S.Ct. 161, 89 L.Ed. 124 (1944).

The General Rules of Interpretation (“GRIs”) and, if applicable, the Additional U.S. Rules of Interpretation (“ARIs”) of the HTSUS provide the analyticalframework for the court's classification of goods. N. Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed.Cir.2001). For additional guidance as to the scope and meaning of tariff headings and notes, the court also may consider the Explanatory Notes (“ENs”) to the Harmonized Commodity Description and Coding System, developed by the World Customs Organization.

Merchandise imported into the United States is classified for tariff purposes under the provisions of the HTSUS. Classification of merchandise under the HTSUS is governed by the principles set forth in the General Rules of Interpretation ("GRIs") and the Additional U.S. Rules of Interpretation ("ARIs"). See, e.g.,North Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed. Cir. 2001). Because both the GRIs and the ARIs are part of the HTSUS, they are considered statutory law for all purposes. See 19 U.S.C. § 1202.

See Orlando Food Corp. v. United States, 140 F.3d 1437, 1439 (Fed. Cir. 1998). The Court begins its analysis with GRI 1. See N. Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed. Cir. 2001). GRI 1 states that "classification shall be determined according to the terms of the headings and any relative section or chapter notes. . . ."

GRI 1 provides that "classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ." The GRI must be applied in numerical order, see North Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed. Cir. 2001); thus, if the application of GRI 1 provides the proper classification, the Court may not consider any of the subsequent GRI. See Mita, 160 F.3d at 712. 1. The PC 101 is a "part"

LSI's reliance on USDA's differing treatment of dehydrated meat products to support its conclusion that the subject beef jerky should be classified by HTSUS 1602.50.2040 is misplaced because, although they may be helpful, non-tariff regulations by other agencies are not dispositive for purposes of tariff classification. North Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed.Cir.2001); Marubeni Am. Corp. v. United States, 35 F.3d 530, 537 (Fed.Cir.1994). Nor do this court's opinions in Arko Foods Int'l, Inc. v. United States, 654 F.3d 1361 (Fed.Cir.2011), and CamelBak support LSI's argument.

Although the Explanatory Notes are not legally binding or dispositive, we may consult them for guidance and they are generally indicative of the proper interpretation of the various HTSUS provisions. JVC Co. of Am. v. United States, 234 F.3d 1348, 1352 (Fed.Cir.2000). See also BenQ Am. Corp. v. United States, 646 F.3d 1371, 1376 (Fed.Cir.2011); N. Am. Processing Co. v. United States, 236 F.3d 695, 698 (Fed.Cir.2001); Carl Zeiss, 195 F.3d at 1378 n. 1. The Explanatory Notes are a publication of the World Customs Organization (WCO).