CLA-2-44:OT:RR:NC:N1:130
Mr. Harro Jakel
PanTim Wood Products
15 Washington Ave.
Scarborough, ME 04074
RE: The tariff classification of solid wood flooring from Indonesia
Dear Mr. Jakel:
In your letter, dated April 9, 2025, you requested a binding classification ruling on solid wood flooring.
Product information and a sample were submitted for our review.
The product under consideration is solid wood flooring panels consisting of rubberwood (Hevea brasiliensis).
Rubberwood is a tropical wood as designated Appellation of Tropical Woods annex to The Explanatory
Notes to the Harmonized System (ENs) for Chapter 44. The panels measure approximately four inches in
width and 18mm in thickness. They are tongued and grooved on all edges and ends and have two shallow
lengthwise grooves on the panel back. The panels may or may not be hand-scraped. The sample is stained,
and you indicate that it is coated with a clear UV-cured urethane.
The solid wood flooring is constructed of a tropical wood and is continuously shaped on its edges, ends, and
back. The panels are coated with UV-cured urethane, essentially a plastic. The ENs to heading 4409
specifically exclude products that are surface-worked beyond planing or sanding, other than painting,
staining, or varnishing. This means that no treatment of the panel surface beyond planing or sanding
(physical working) or painting, staining, or varnishing (coatings) are allowable in heading 4409. The panels
that are hand-scraped are “surfaced worked beyond planing or sanding”. UV-cured urethane is also a
treatment of the panel surface that is beyond paint, stain, or varnish. So, due to the hand-scraping and the
coating with urethane, classification in heading 4409 is precluded. Wood flooring is a recognizable article
used in the construction of a building, so classification in heading 4418 as builders’ joinery is appropriate.
The applicable subheading for solid rubberwood flooring will be 4418.99.9105, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for Builders' joinery and carpentry of wood, including cellular
wood panels and assembled flooring panels; shingles and shakes: Other: Other: Other: Wood flooring. The
rate of duty will be 3.2 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs.? All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries, including Indonesia, will be subject to an additional 10 percent ad valorem rate of duty. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in
addition to subheading 4418.99.9105, HTSUS, listed above.
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