CLA-2-44:OT:RR:NC:N5:130
Colin Miller
Clarke Veneers and Plywood
3000 Old Canton Road, Suite 335
Jackson, MS 39216
RE: The tariff classification of multilayer wood panels from Mexico
Dear Mr. Miller:
In your letter dated August 6, 2025, you requested a tariff classification ruling on multilayer wood panels.
Product information was submitted for review.
The product under consideration is a three-ply wood panel. The panel is constructed of a face and back ply of
wood veneer that measures approximately 0.5mm to 0.6mm in thickness, and a core of medium density
fiberboard (MDF) that ranges from 5.2mm to 19mm in thickness. The panels measure approximately 4’ wide
by 8’ long and in thickness ranging from 6.2mm to 20.2mm. You state the face ply may consist of one of
several non-coniferous woods including maple (Acer spp.), red oak (Quercus rubra), white oak (Quercus
alba), alder (Alnus spp.), beech (Fagus spp.), ash (Fraxinus spp.), birch (Betula spp.), or walnut (Juglans spp.
). The back ply will be the same species as the face ply but of a lower grade. You state the panels have a
straight-cut edge with an unfinished surface where the grain remains visible. You indicate these panels are
intended for fabrication into furniture, cabinetry, fixtures, and architectural millwork.
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).
You question whether these wood panels are classifiable as veneered panels of heading 4412, HTSUS, or as
medium density fiberboard (MDF) of heading 4411, HTSUS.
The Explanatory Notes (ENs) to the Harmonized System for heading 4412 specifically define “veneered
panels” as “panels consisting of a thin veneer of wood affixed to a base, usually of inferior wood, by gluing
under pressure.” The instant wood panel meets this description, as the veneer gives the panel its essential
character, and the veneer is affixed to a base of MDF. Veneered panels are specifically provided for in the
language of heading 4412, Harmonized Tariff Schedule of the United States (HTSUS).
While fiberboard products are classified in heading 4411, HTSUS, the Explanatory Notes (ENs) to heading
4411 specifically exclude products covered in wood veneer: “This heading does not cover (b) Laminated
wood with a core consisting of fibreboard (heading 44.12). Therefore, the instant panel with outer plies of
nonconiferous wood and a fiberboard core is precluded from heading 4411, HTSUS.
The applicable subheading for the three-ply wood panels with outer plies of nonconiferous wood and a
fiberboard core will be 4412.92.5215, Harmonized Tariff Schedule of the United States (HTSUS), HTSUS,
which provides for Plywood, veneered panels and similar laminated wood: Other: Other, with at least one
outer ply of nonconiferous wood: Other: Other: Other. The rate of duty will be free.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 4412.92.5215,
HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 4412.92.5215, HTSUS.
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 of Mexico are not
subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.01.27, in addition to subheading 4412.92.5215, 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)
Denise Faingar
Acting Director
National Commodity Specialist Division