CLA-2-94:OT:RR:NC:N4:433
Rebecca D. Gammon, LCB
National Compliance Specialist
UTi United States, Inc.
3717 Wilson Road, Suite 100
Atlanta, GA 30354
RE: The tariff classification of drawer components from China.
Dear Ms. Gammon:
In your letter dated March 5, 2013 and received April 05, 2013, on behalf of MJB Wood Group, Inc. (MJB), you requested a tariff classification ruling. Four unidentified samples of grooved wood pieces were received.
Item number 012213-1 is described as the sides and backs of drawer boxes for cabinets and other furniture. The drawer sides and backs are approximately 7/16 of an inch to ¾ of an inch thick, and can be solid to width, or edge-glued and solid to length or finger-jointed. A ¼ inch groove is cut along the lower edge of each board which will be used to hold the drawer bottom. A lacquer, varnish and/or polymer coat is typically applied to each board to help maintain stable moisture content and protect the wood. These drawer components can be made of birch, or a combination of poplar, aspen and cottonwood.
You state in your letter that the grooved drawer sides and backs may be imported cut to length and ready for assembly into finished drawers, or imported in lengths of +/- 96 inches (8 foot lengths or less) to allow for custom sizing. After importation, MJB’s customers will assemble the finished boxes by fitting the drawer bottoms and attaching the hardware. No information was provided concerning the front panel assembly.
While the sides and backs of drawer boxes, cut to length, grooved and ready for assembly are identifiable parts of furniture, the 8 foot lengths or less not cut to size and ready for assembly, even though grooved, are not considered identifiable or recognizable parts of furniture. As such, the 8 foot lengths or less not cut to size and ready for assembly prior to being imported are to be classified based upon their constituent material. The edge-gluing of the wood, in addition to the lacquer and polymer finishes, precludes classification of the components in heading 4409 of the Harmonized Tariff Schedule of the United States (HTSUS).
The applicable subheading for the drawer sides and backs in 8 foot lengths or less, grooved, not cut and ready for assembly, will be 4421.90.9780, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of wood: Other: Other: Other: Other.” The rate of duty will be 3.3 percent ad valorem.
The applicable subheading for drawer sides and backs, imported cut to length and ready for assembly into drawer boxes, will be 9403.90.7080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other furniture and parts thereof: Parts: Other: Of wood; Other.” The rate of duty will be free.
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 drawer sides and backs imported in 8 foot or less lengths, not cut and ready for assembly, contact National Import Specialist Laurel Duvall at (646) 733-3035. If you have any questions regarding the drawer sides and backs, pre-sized and ready for assembly, contact National Import Specialist Neil H. Levy at (646) 733-3036.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division