CLA-2-44:OT:RR:NC:N5:130
Mr. Andy Littig
Larson-Juhl
1925 Breckenridge Plaza
Duluth, GA 30096
RE: The tariff classification of picture frame moldings from Italy
Dear Mr. Littig:
In your letter, dated August 20, 2025, you requested a binding tariff classification ruling on picture frame
moldings. The request was returned to you for additional information, which was received by this office on
September 9, 2025. Product information and samples were submitted for our review.
The products under consideration are multiple picture frame moldings. Each molding is made of
continuously shaped Ayous wood (Triplochiton scleroxylon, a tropical wood). The profile is generally an
L-shape allowing for a smooth, rectangular picture frame. The picture frame moldings are coated with a
paint with a specially added hardener allowing for the paint to build up and obscure the sight and texture of
the grain of the wood.
In your letter you suggest that the picture frame moldings are classifiable under subheading 4409.22.5060,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree. The Explanatory Notes to heading
4409 specifically exclude “Wood which has been surface worked beyond planing or sanding, other than
painting, staining or varnishing (e.g., veneered, polished, bronzed, or faced with metal leaf).” The treatment
of the moldings with the hardener is surface working beyond paint, stain, or varnish. The moldings are thus
classifiable in heading 4421.
The applicable subheading for the picture frame moldings will be 4421.99.9880, HTSUS, which provides for
Other articles of wood: Other: Other: Other: Other: Other. The general 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 of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e., 9903.02.20, 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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division