Max Chen
Merlon Ltd.
Room 1902, Easey Commercial Bldg.
253-261 Hennessy Road
Wanchai, Hong Kong

RE: The tariff classification and country of origin of laminated truck flooring

Dear Mr. Chen:

In your letter, dated March 18, 2022, you requested a tariff classification and country of origin ruling on laminated wood flooring used in trucks and trailers. Detailed information on the product and manufacturing operations were provided for our review.

The finished flooring panels consist of red oak laminated boards connected end-to-end by finger jointing and side-to-side by edge gluing. The panels will come in varying sizes, measuring between 1058-15898 mm in length by 103-350 mm in width by 28-35 mm in thickness with lap joinery on both edges.

First we will address classification. You propose that the truck bed flooring panels are classifiable in heading 4407. We disagree. Heading 4407 provides for wood that is end jointed, but not edge jointed. Furthermore, the panels are continuously shaped throughout their length in a shiplap configuration. Both the edge-gluing and the continuous shaping both preclude classification in heading 4407. The truck bed flooring panels are wood that has been continuously shaped along their edges (rabbet or "lap"). However, because the panels are constructed of edge-glued wood, they are precluded from classification in 4409. Because they are flooring that is utilized in trucks, the panels are not builders' joinery (i.e., recognizable articles used in the construction of a building) of heading 4418. Therefore, classification advances to heading 4421.

The applicable subheading for the truck flooring will be 4421.99.9880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of wood: Other: Other: Other: Other: Other.” The rate of duty will be 3.3 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

We now turn to the country of origin issue. You describe the manufacturing process as follows: Red oak lumber measuring from1800-5000 mm in length by 76-550 mm in width by 25.4 mm in thicknes are sourced in the United States. The U.S. lumber is shipped to mainland China where the lumber is cut into strips; all defects, such as knots and cracks, are removed; finger joint tennons are machined at the two ends of each strip; the strips are connected in length by finger joints and bonded together side-by-side with melamine glue. Finally, they are grooved and planed before packaging. You add that the raw material red oak makes up approximately 85% of the cost of the final product.

Section 304 of the Tariff Act of 1930 (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article.

Part 134, U.S. Customs and Border Protection (“CBP”) Regulations (19 C.F.R. Part 134), implements the country of origin marking requirements of 19 U.S.C. § 1304. Title 19, Section 134.1(b) defines “country of origin” as “the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the ‘country of origin’ within the meaning of this part; ….” A substantial transformation occurs when as a result of a process an article emerges, having a distinctive name, character or use from the original material subjected to the process. If the manufacturing process is a minor one, which leaves the identity of the imported article intact, a substantial transformation has not occurred. See Uniroyal, Inc. v. United States, 3 CIT 220, 542 F. Supp. 1026 (1982), aff’d per curiam, 702 F.2d 1022 (Fed. Cir. 1983).

In China the raw lumber is transformed into finished flooring, constituting a substantial transformation. The flooring has a new name, character and use different from the raw lumber. As a result, the country of origin of the truck flooring is China.

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, 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 and, respectively.

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