MAR-2-44:OT:RR:NC:N5:130
Mr. Drew Dowd
Adentra Imports
2700 Lind Ave SW
Renton, WA 98057
RE: The country of origin of veneer edge banding
Dear Mr. Dowd:
In your letter, dated June 10, 2025, you requested a binding country of origin ruling on veneer edge banding
for duty purposes. Product information and photos were submitted for our review.
The product under consideration is veneer edge banding. The edge banding will be imported in rolls
measuring 24mm or 48mm wide by 100 meters in length. The edge banding will be approximately 0.6mm in
thickness. You do not identify the species of wood that will be used for the edge banding.
In your letter, you outline a scenario wherein veneers are peeled from logs in China. The veneers will then be
shipped to Belgium where they are cut to standardized widths. The veneers will be end-jointed to create
longer lengths. A thin fleece backing will be applied to the veneer for stabilization. The veneers will be
subjected to quality control measures and then fed through a sanding and finishing line multiple times, during
which a UV-cured clear coating will be applied to the surface. After final trimming, the edge banding is
complete.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
The product manufactured in China is wood veneers. Wood veneers are classifiable in heading 4408. The
Explanatory Notes to the Harmonized System explain that wood veneers are wood
in sheets of a thickness not exceeding 6 mm (excluding any reinforcing material), obtained by sawing,
slicing or peeling (rotary cutting), whether or not smoothed, dyed, coated or impregnated, or
reinforced with paper or fabric backings, or in decorative sheets imitating marquetry.
The veneers are backed with fleece, which does not preclude them from classification in heading 4408. The
heading language of heading 4408 provides for
Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for similar
laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded,
spliced or end-jointed, of a thickness not exceeding 6 mm:
This language makes it clear that veneers may be sanded, spliced, or end-jointed, and they are still considered
to be veneers of heading 4408. There are no operations that take place in Belgium that result in a product that
is something other than veneers. The original product from China – veneers – remain veneers even after the
manufacturing operations. Therefore there is no substantial transformation that takes place in Belgium.
The country of origin of the edge banding is China.
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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division