CLA-2-44:OT:RR:NC:N5:130
TARIFF NO: 4421.99.9880; 9903.01.25
Ms. Eileen Family
Geodis USA, LLC
5101 S. Broad St.
Philadelphia, PA 19112
RE: The tariff classification of wood drawer sides, fronts, and backs from multiple countries
Dear Ms. Family:
In your letter, dated July 3, 2025, you requested a binding tariff classification ruling on behalf of your client,
Cabinetworks Group. The ruling was requested on wood drawer sides, fronts, and backs from multiple
countries. Product information and photos were submitted for our review.
The products under consideration are drawer sides, fronts, and backs. The boards measure 18”, 21” or 24” in
length and are of varying widths. The wood boards are edge-glued and are continuously shaped with a
squared groove that accommodates the drawer bottom when the drawer is assembled. The boards are coated
with a UV-cured coating. The boards are constructed from birch wood in Estonia, or from rubberwood in
Vietnam, Malaysia, Thailand, or Indonesia.
In your letter, you argue that the drawer components are classified as wood parts of furniture in subheading
9403.91.0080, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. You state that the
boards are imported in ready-to-assemble condition. This is contradicted by your statement that “The only
additional simple processing that occurs post importation is the dovetailing and rabbeting that allow for the
interlocking of the drawer parts.” Dovetailing and rabbeting are significant operations that change the drawer
components from undedicated, continuously shaped wood to dedicated drawer parts. The drawer
components, in their condition as imported, are not recognizable as complete, ready to assemble drawer parts;
they are merely continuously shaped wood.
While continuously shaped wood is provided for in heading 4409, the instant goods are precluded from
classification therein. First, the boards are constructed of edge-glued wood. Edge-glued wood is not
classifiable in heading 4409 as heading 4409 provides only for end-jointed wood. Furthermore, the boards
are coated with a UV-cured plastic coating. The Explanatory Notes to heading 4409 specifically exclude
wood that has been surface worked beyond painting, staining, or varnishing. UV-cured coatings are not
paint, stain, nor varnish, and therefore are beyond those limits. The boards are therefore classifiable in
heading 4421.
The applicable subheading for the wood drawer sides, fronts, and backs will be 4421.99.9880, HTSUS,
which provides for Other articles of wood: Other: Other: Other: Other: Other. The rate of duty will be 3.3
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. At this time products from all countries,
including Estonia, Vietnam, Malaysia, Thailand, and 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 4421.99.9880, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division