CLA-2-44:OT:RR:NC:N5:130
Mr. Harro Jakel
PanTim Wood Products
15 Washington Ave.
Scarborough, ME 04074
RE: The tariff classification of multilayer wood flooring from Thailand
Dear Mr. Jakel:
In your letter, dated April 22, 2025, you requested a binding classification ruling on multilayer wood
flooring. Product information and a sample were submitted for our review.
The product under consideration is a multilayer wood flooring panel. The flooring panel is constructed of 3
wood plies. The face ply, measuring 3.8mm in thickness, consists of a continuous sheet of white oak
(Quercus spp., a non-coniferous wood) wood veneer. The center ply, measuring approximately 9mm in
thickness, consists of blocks of spruce (Picea spp., a coniferous wood) wood. The back ply, measuring
approximately 2mm in thickness, consists of radiata pine (Pinus radiata, a coniferous wood) veneer. The
grain of the center ply runs at a 90-degree angle to that of the face and back plies. The surface of the face ply
is coated with a clear urethane that does not obscure the face ply. The panel is tongued and grooved on its
edges and ends.
In understanding the language of the Harmonized Tariff Schedule of the United States (HTSUS), the
Explanatory Notes to the Harmonized System (ENs) may be utilized. The ENs, although not dispositive nor
legally binding, provide a commentary on the scope of each heading of the HTSUS, and are the official
interpretation of the Harmonized System at the international level. See T.D. 89-80, 54 Fed. Reg. 35127,
35128 (August 23, 1989). “Plywood” is defined in the ENs for heading 4412, HTSUS: a panel “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. The ENs also describe
“blockboard” as panels “in which the core is thick and composed of blocks, laths or battens of wood glued
together and surfaced with the outer plies.” This also describes the instant panels. Both plywood and
blockboard are specifically provided for in heading 4412 of the HTSUS.
The applicable subheading for the multilayer wood flooring panels with face ply of oak, will be
4412.52.3105, HTSUS, which provides for Plywood, veneered panels and similar laminated wood:
Blockboard, laminboard and battenboard: Other (than With at least one outer ply of tropical wood), with at
least one outer ply of nonconiferous wood: Plywood: 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: Other: Wood
flooring. The rate of duty will be 8 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 Thailand, 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 4412.52.3105, 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Laurel Duvall at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division