Mr. Guy Rainwater
ITS Inc.
30664 Emperor
Canyon Lake, CA 92587

RE: The tariff classification of furniture-grade plywood panels from China

Dear Mr. Rainwater:

In your letter, dated May 1, 2018, you requested a binding tariff classification ruling. The ruling was requested on plywood panels used for furniture manufacturing. A sample was submitted with your ruling request and was forwarded for laboratory analysis. This analysis has been completed. We apologize for the delay in our reply.

The plywood panel submitted measures 18mm in thickness. It is constructed of 11 plies of wood, each ply measuring approximately 1.5mm in thickness. The outer plies consist of European Red Pine (Pinus sylvestris), a coniferous wood. The core consists of 9 poplar plies. The grain of each of the plies runs at a 90-degree angle to that of the subsequent plies. The panels are sometimes sanded for calibration.

Plywood is defined in the Explanatory Notes for heading 4412, Harmonized Tariff Schedule of the United States (HTSUS), as “consisting of three or more sheets of wood glued and pressed one on the other and generally disposed so that the grains of successive layers are at an angle.” This definition describes the instant panels. Plywood is specifically provided for in heading 4412 of the HTSUS, and the panels are classified in that heading in accordance with General Rule of Interpretation 1.

The applicable subheading for the plywood panels with outer plies of European Red Pine will be 4412.39.3000, HTSUS, which provides for Plywood, veneered panels and similar laminated wood: Other plywood consisting solely of sheets of wood (other than bamboo), each ply not exceeding 6 mm in thickness: Other, with both outer plies of coniferous wood: 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: With a face ply of European red pine (Pinus silvestris) The rate of duty will be 3.4 percent ad valorem.

Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.

Products of China classified under subheading 4412.39.3000, HTSUS, unless specifically excluded, are subject to the additional 10 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 4412.39.3000, HTSUS, listed above.

The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.

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

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


Steven A. Mack
National Commodity Specialist Division