CLA-2-44:OT:RR:NC:4:434
Borja Gonzalez
L’antic Colonial
Carretera Nacional 340, KM 54
Villareal
Spain
RE: The tariff classification of wooden mosaic pieces from China
Dear Mr. Gonzalez:
In your letter dated April 22, 2025, you requested a tariff classification ruling. The ruling was requested on
wooden wall mosaic pieces. Photos and a detailed description were submitted for our review.
The product under consideration you describe as a decorative wood mosaic, specifically “Wood Tetra Oak”
or “Wood Tetra Walnut,” depending on the species of wood. Small pieces (approximately 4” by 3.5”) of
stained, solid walnut or oak are glue-mounted to a mesh backing made of plastic. The mosaics are imported
in sheets sized 8” by 15”. The mosaic pieces are designed to be adhered to a wall as a decorative covering, as
an alternative to paint or wallpaper.
You propose classification in subheading 4418.99.9195, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Builder’s joinery and carpentry of wood, including cellular wood panels and
assembled flooring panels; shingles and shakes…Other.” We disagree. The mosaic sheets are not structural
and therefore not used in the construction of a building, precluding classification in heading 4418.
The applicable subheading for the decorative wooden mosaic pieces will be 4421.99.9880, HTSUS, which
provides for Other articles of wood. 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 World Wide Web at http://www.usitc.gov/tata/hts/.
You further request a determination of whether the goods fall within the scope of antidumping/countervailing
orders (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement
and Compliance office in the International Trade Administration of the Department of Commerce (ITA) and
are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP).
General information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, 9903.01.24, in addition to
subheadings 4421.99.9880, HTSUS, listed above.
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. At this time products from all countries
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, 9903.01.25, in addition to subheading
4421.99.9880, HTSUS, listed above.
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, you may refer to the relevant parts of the USTR and CBP websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Regulations (19 CFR 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].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division