CLA-2-44:OT:RR:NC:1:230

Ms. Ines Way
Cali Bamboo, LLC
9365 Waples St.
Suite D
San Diego, CA 92121

RE: The classification of engineered bamboo flooring from China

Dear Ms. Way:

In your letter, dated August 9, 2017, you requested a binding classification ruling. The ruling was requested on engineered flooring with a strand bamboo face ply. A sample was submitted for our review and will be retained for reference.

We note that the product addressed in this ruling is similar to that addressed in New York Ruling N287566, but is not identical. This ruling does not replace nor negate ruling N287566. Because of the existence of two such similar rulings, shipments may be subjected to additional scrutiny to determine the correct classification of the imported goods. The subject flooring is marketed as “Antique Java Fossilized Bamboo Flooring”, identified by style number 7012001000. The sample is a flooring panel measuring approximately 7 1/2” (W) and 14.9 mm thick. In their condition as imported, you state that the panels are 72 7/8” in length. The panel consists of seven plies. The face ply is a veneer of strand woven bamboo measuring approximately 4.2mm in thickness. The core consists of eucalyptus veneers, and the back ply is a poplar veneer. None of the plies exceeds 6mm in thickness. The grain of each ply runs at a 90 degree angle to that of the subsequent plies. The panels are tongued and grooved on all edges and ends, and have been finished with 13 layers of a clear coat, scratch- resistant finish that does not obscure the grain of the wood.

Additional U.S. Note 4(b) to Chapter 44, Harmonized Tariff Schedule of the United States (HTSUS), states that heading 4418 includes multi-layer assembled flooring panels having a face ply of 4 mm or more in thickness. The panel constitutes flooring, consists of multiple layers, and has a face ply greater than 4mm in thickness.

The applicable subheading for the engineered bamboo flooring will be 4418.73.7000, HTSUS, which provides for Builders' joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and shakes: Assembled flooring panels: Of bamboo or with at least the top layer (wear layer) of bamboo: Other, multilayer: Other: Other. The rate of duty will be 5 percent ad valorem. 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 Laurel Duvall at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division