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 Indonesia
Dear Mr. Jakel:
In your letter, dated September 8, 2025, you requested a binding tariff classification ruling on multilayer
wood flooring. Product information and samples were submitted for our review.
The products under consideration are multilayer wood flooring panels in multiple shapes, including rectangle,
hexagon, and rhombus. For each, the face ply is a single, solid veneer, and is not constructed of multiple
shapes or strips laminated together. The flooring panels are constructed of three wood plies. The panel
samples measure approximately 12mm in thickness. The face ply of each panel measures 3mm in thickness
and consists of white oak, a non-coniferous wood. The core measures just over 6mm in thickness and
consists of pine lumber blocks. The back layer will measure 3mm in thickness and consists of rubberwood (
Hevea spp., a tropical wood). The grain of the center ply runs at a 90-degree angle to that of the face and
back plies. The panels are tongued and grooved along their edges and ends. The face is covered with a clear
material that does not obscure the grain.
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.
Note 4 to Chapter 44 provides that:
Products of heading 4410, 4411 or 4412 may be worked to form the shapes provided for in respect of
the articles of heading 4409, curved, corrugated, perforated, cut or formed to shapes other than square
or rectangular or submitted to any other operation provided it does not give them the character of
articles of other headings.
Because the flooring panels do not have the character of goods of headings other than 4412, the hexagonal
and rhomboid shapes do not impact classification. Therefore, each of the panels is classifiable in heading
4412, HTSUS.
The applicable subheading for the 3-ply multilayer wood flooring panels with a 3mm-thick face ply of white
oak and a 3mm-thick back ply of rubberwood will be 4412.51.3105, HTSUS, which provides for Plywood,
veneered panels and similar laminated wood: Blockboard, laminboard and battenboard: With at least one
outer ply of tropical 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. At this time, products of Indonesia will
be subject to an additional ad valorem rate of duty of 19 percent. However, your product falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e., 9903.01.32, in addition to subheading 4412.51.3105, 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