CLA-2-44:RR:NC:2:230 F82107

Mr. Bernard D. Arbit
Arbit Trading Corp.
One Warburton Ave.
Hastings-on-Hudson, NY 10706

RE: The tariff classification of a birch plywood surface covered with plastic from Finland

Dear Mr. Arbit:

In your letter dated January 4, 2000 you requested a tariff classification ruling.

The ruling was requested on a birch plywood laminated with a tradenamed plastic material called Rayform DuraCore and Rayform DuraPly. The difference between the two types is the thickness of the material. Sample sections of the Rayform plastic material and of the birch plywood laminated with the Rayform plastic were submitted.

Rayform plastic is manufactured in the United States. You intend to ship this plastic material to Finland where it will be laminated to a birch plywood core. The plastic will be laminated to one or both sides of a birch core. The birch core may be ¼”, 3/16”, ½” or 9/16” thick.

The sample of the product to be imported consists of a five ply birch plywood approximately ½” thick with a 1/16” thick layer of Rayform plastic laminated to both surfaces. The laminated Rayform plastic material has the appearance of a gray stone-like sheet. The edges and ends of the plywood are open and square.

Rayform covered plywood will generally be used as dieboards. They may, however, also be used as countertops and similar applications. All imports will be rectangular or square in shape. The applicable subheading for birch plywood surface covered with Rayform plastic will be 4412.14.5500, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for plywood consisting solely of sheets of wood, each ply not exceeding 6 mm in thickness; other, with at least one outer ply of nonconiferous wood; other (than not surface covered or surface covered with a clear or transparent material which does not obscure the grain texture or markings of the face ply). The rate of duty will be 8 percent ad valorem.

The duty is applicable on the full value of the goods being imported including any assists supplied to the foreign manufacturer.

In certain cases, an allowance may be taken for American goods assembled abroad. Additional detailed information regarding the condition of the plastic material when exported to Finland and the processing steps performed in Finland would be required in order to determine if the allowance is applicable. A separate ruling request should be submitted for us to determine the applicability of an allowance for assembled American components. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 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, contact National Import Specialist Paul Garretto at 212-637-7009.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division