CLA-2-44:RR:NC:2:230 I84103

Mr. Douglas G. McKenny
Norman G. Jensen, Inc.
395 Caswell Avenue
P.O. Box 1439
Derby Line, VT 05830

RE: The tariff classification of door jambs, headers and stiles from Canada

Dear Mr. McKenny:

In your letter dated July 8, 2002, on behalf of your customer Bois Gous (aka Goulet & Fils Ltee.), you requested a tariff classification ruling. The ruling was requested on door hinge stiles, latch stiles and rails and on door jambs and headers. The hinge stiles, latch stiles and rails are interior parts of doors. The door jambs and headers are parts of the frames that finish the wall around a door. Nine representative samples of the products were submitted. The products are made from finger-jointed white pine.

The sample marked C-1 is a hinge stile measuring approximately 1-5/8” wide by 1-3/16” thick. It has two grooves running down the length on one surface. The purpose of the grooves is stated to be for holding the steel door faces in the manufacture of a steel door. The sample marked C-2 is a latch stile with the same dimensions as C-1 and with the same grooves on one surface. In addition, C-2 has four grooves running down the length of the back surface. The hinge stile (C-1) forms the inside vertical part of a door to which a hinge is attached. The latch stile (C-2) forms the inside vertical part of a door to which a latch is attached. The stiles will be imported in lengths of 79.375” or other similar precision lengths. The ends are square cut.

The sample marked D-1 is a door jamb and door stop combination molding. It is a single continuously shaped piece of finger-jointed wood measuring approximately 4-9/16” wide by 3/4” thick for half the width and 1-1/4” thick for the other half containing the door stop section. A ½” wide slit runs along the surface between the door stop and door jamb sections. The slit facilitates the application of weather stripping. In addition, the back of the door jamb has several shallow grooves running down the length. One end of sample D-1 has a ½” deep by 1-1/4” long cutout (referred to as a dadoed end by your customer). The cutout removes the door stop part of the molding for 1-1/4” at the end. The purpose of the cutout is to receive the door header represented by sample D-2. Your customer states the other end of item D-1 (which was not shown on the sample section submitted) is cut off at an angle to fit with a door sill and allow for water evacuation. The door jamb will be imported in lengths of 82.031” or other similar precision lengths.

The sample marked D-2 is a door header and door stop combination molding identical in construction to sample D-1. It differs in that it is not cut out or otherwise worked on any end. In addition, it is imported in lengths of 35.9375” or other similar precision lengths. The header forms the top horizontal portion of a door frame and the jamb forms the vertical side portion of a door frame. Jambs and headers finish and trim the wall around a doorway and are recognized as moldings.

The sample marked E is a door jamb and door stop combination molding identical in construction to sample D-1. It has one cut out end like sample D-1. However, the other end is not cut out or otherwise worked. In addition, it may be primed.

The applicable subheading for the molding with unworked ends (the door header -sample D-2) will be 4409.10.4000, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for wood continuously shaped along any of its edges, ends or faces, coniferous, standard wood moldings, pine. The general rate of duty will be free.

The applicable subheading for the moldings with cutouts as described above (the door jambs - samples D-1 and E) will be 4418.90.4590, HTSUSA, which provides for builders’ joinery and carpentry of wood, other, other. The general rate of duty will be 3.2 percent ad valorem. The applicable subheading for the door parts with unworked ends, (the door stiles - samples C-1 and C-2) will be 4409.10.9040, HTSUSA, which provides for wood continuously shaped along any of its edges, ends or faces, coniferous, other, other. The general duty rate will be free.

Your inquiry does not provide enough information for us to give a classification ruling on samples marked A-1, A-2, B-1 and B-2 (door stiles and rails with dadoed ends). Your request for a classification ruling should (1) explain whether any further manufacturing, processing or cutting is done to these products after importation and if so, give a detailed description of such processing. (2) Please clarify the dimensions that these products will be imported in. Include the unit of measurement. (3) Please furnish labeled diagrams to correspond with the descriptions of the grooves and cuts of these products. Certain grooves mentioned in the descriptions could not be located. Conversely, we found grooves that were not described. (4) Please explain why sample A-1has the longitudinal grooves on the inside while sample A-2 has the same grooves on the outside when the two are put together at the dadoed ends as intended. (5) Please explain what “capping” means. Is capping necessary on all four edges of a door? (6) Please give a step-by-step description of how a door is manufactured from these products. When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include all of the material that we have returned to you.

The door stiles (samples C-1 and C-2) may be subject to antidumping duties and/or countervailing duties. A list of AD/CVD proceedings at the Department of Commerce (DOC) and their product coverage can be obtained from the DOC website at: http://ia.ita.doc.gov, or you may write to them at the U.S. Department of Commerce, International Trade Administration, Office of Antidumping Compliance, 14th Street and Constitution Avenue, N.W. Washington, DC 20230. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs.

The holding 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 19 CFR 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, either directly, by reference, or by implication, is accurate and complete in every material respect.

This ruling is being issued under the assumption that the subject goods, in their condition as imported into the United States, conform to the facts and the description as set forth both in the ruling request and in this ruling. In the event that the facts or merchandise are modified in any way, you should bring this to the attention of Customs and you should resubmit for a new ruling in accordance with 19 CFR 177.2. You should also be aware that the material facts described in the foregoing ruling may be subject to periodic verification by the Customs Service.

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 646-733-3035.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division