Ms. Yvonne Tan
735 West Emerson Ave
Monterey Park, CA 91754
RE: The tariff classification door stiles from China
Dear Ms. Tan:
In your letter, dated December 2, 2022, you requested binding tariff classification ruling on behalf of your client, Plastpro 2000 Inc. The request is for the classification of door stiles constructed of polyvinyl chloride (PVC) and laminated veneer lumber (LVL) or similar wood material. Product information and photos were submitted for our review.
The request concerns door stiles that are made from a combination of LVL or similar wood material and a PVC cap. Door stiles are the vertical members that generally make up the interior framework of a flush door. The instant stiles are designed for the construction of fiberglass doors. The stiles are identified as "strike" and "hinge" based on the edge of the door that they form. The LVL or similar wood material is constructed of poplar wood veneers laminated together with their grains parallel. All of the stiles have a similar construction with a body of LVL or similar wood material of varying thickness and profile. The PVC cap is the same for each stile; it measures approximately 0.4" in thickness, is equal to the width of each stile, and is continuously profiled along its length with a channel on either side. The PVC cap forms the exposed edge of the door when the stile is installed. Each complete stile has a continuous, non-rectangular profile throughout its length.
In your submission, you identify 5 stile items: Strike Stiles 68V, 68, and 80, and Hinge Stiles 68 and 68I. The LVL in the strike stiles is constructed with many veneers laminated together, one on top of the next, with the PVC cap applied to the face. The wood material in the hinge stiles is similar to LVL but is oriented "on its side" with the veneers side by side and the cap oriented perpendicular to the veneer faces. On each stile, the PVC extends inches beyond the end of the wood material for assembly with a door rail.
Strike stile 68V measures 1.585" wide by 3.175" thick; it has a back groove ("vent slot") and six side channels that run the full length of the stile. The LVL is approximately 2.775" thick, or about 87% of the thickness of the stile. Strike stile 68 is the same as 68V, but does not have the back groove. Strike stile 80 measures 1.585" wide by 1.457" thick. The LVL is about 1.057" thick, or about 72.5% of the thickness of the stile. It has a rabbet profile at each edge of the stile back. Hinge stiles 68 and 68I are identical except that 68 measures 1.585" wide and 68I measures 1.485" wide. The wood material in both stiles is about 1.067" thick, or about 62.5% of the thickness of the stile. All of the stiles measure either 79.438" or 95.438" in length.
In your letter, you suggest that the stiles are composite goods that are classifiable as PVC under subheading 3925.20.0091, Harmonized Tariff Schedule of the United States (HTSUS), which provides for builders' wares of plastic. We disagree. The stiles are not composite goods, but rather a specific structural article that is dedicated for use as a door stile. They are not classifiable as plastic because, in no case does the PVC content predominate; the wood content predominates in each stile. The stiles are not classifiable as LVL in heading 4412. The stiles are not builders' joinery of heading 4418 because, while heading 4418 provides for doors of wood, it does not provide for parts thereof. A door stile is not an article used in the construction of a building, but is, instead, an article used in the construction of a door. Therefore, the stiles are classifiable as other articles of wood in heading 4421. Please see Headquarters Rulings H039043 and H286414.
The applicable subheading for the five door stiles will be 4421.99.9880, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other: Other. The rate of duty will be 3.3 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4421.99.9880, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 4421.99.9880, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD) for moldings and millwork from China, A570-117/C570-118. Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at https://trade.gov/enforcement/ (click on "Contact Us"). For your information, you can view a list of current AD/CVD cases at the Department of Commerce ITA website at https://www.trade.gov/data-visualization/adcvd-proceedings, and you can search AD/CVD deposit and liquidation messages using CBP's AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the World Wide Web at https://hts.usitc.gov/current.
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 Charlene Miller at [email protected].
Steven A. Mack
National Commodity Specialist Division