CLA-2-44:OT:RR:NC:2:230
Ms. Ayonna Sain
Mallory Alexander
4294 Swinnea Road
Memphis, TN 38118
RE: The tariff classification of door stiles and raised door panels from Honduras
Dear Ms. Sain:
In your letter dated March 18, 2010 you requested a tariff classification ruling. The ruling was returned to you for additional information which was resubmitted to this office on April 23, 2010.
The ruling was requested on door stiles and raised door panels. A sample of both items was submitted for our review. The door stile and the raised door panel are both composed of mahogany wood (Swietenia spp). You state that the mahogany is purchased in Nicaragua. The lumber is then machined on all four sides to specific thicknesses and widths. The wood is then shipped to Honduras for further processing into the condition as imported.
In the condition as imported, the door stiles are composed of seven (7) individual mahogany boards face-glued together. Each stile contains a square hole that runs vertically throughout its length, 19 mm from one surface. The hole is a groove on the face of one of the boards that becomes a square hole when the boards are face-glued. The purpose of the hole in the stile is for a concealed multi-point locking system to be installed for security and performance of the door. The door stile sample submitted measures approximately 6” (L) x 5 5/8” (W) x 2 1/8” in thickness. The stiles will be used in the assembly of entry doors.
In the condition as imported, the raised door panels are composed of two (2) layers of mahogany, each over 6 mm in thickness, that are planed to a specific thickness and ripped to a specific width. The pieces are then edged-glued for overall panel width and face glued to give overall panel thickness. The panels are machined to create a decorative profile along the edges and the ends. The submitted sample of the raised door panels measures approximately 21 ½” (L) x 6” (W) x 1 3/8” in thickness. The panels will be used in the assembly of entry doors.
You suggest that the door stile and the raised door panel might be classifiable under 4418.20.8060, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for builders’ joinery and carpentry of wood; doors and their frames and thresholds, other.
The EN to heading 44.18 states as follows:
This heading applies to woodwork, including that of wood marquetry or inlaid wood, used in the construction of any kind of building…
The door stiles and the door panels are used in the assembly of doors and not in the construction of a building; therefore they are not classifiable under heading 4418 as you suggested.
The applicable subheading for the door stiles and the raised door panels will be 4421.90.9760, HTSUS, which provides for other articles of wood. The rate of duty will be 3.3 percent ad valorem.
Importation of these products may be subject to import regulations administered by the U.S. Department of Agriculture (U.S.D.A.). Information regarding applicable regulations administered by the U.S.D.A. may be addressed to that agency at the following location:
U.S. Department of Agriculture
A.P.H.I.S., PPQ
4700 River Road, Unit 136
Riverdale, MD 20737
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 World Wide Web at http://www.usitc.gov/tata/hts/.
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