CLA-2-94:OT:RR:NC:N5:433
Kris Klapprodt
Forest Products Distributors
4200 Beach Drive, Suite 2
Rapid City, SD 57702
RE: The tariff classification and country of origin of wooden furniture components.
Dear Mr. Klapprodt:
In your letter dated September 26, 2025, you requested a tariff classification and country of origin ruling. In
lieu of samples, illustrative literature, a description, and a manufacturing synopsis is provided for review.
Item BAMB30125MI, the “Bamboo Shelf Panel” is a series of bamboo shelf components with six metal
screw inserts that will be used as computer monitor risers, bookshelf components, and in other furniture
applications. The bamboo shelf components will be available in brown, dark brown, and black stain
finishes. In the condition at the time of U.S. importation, the bamboo shelf panel components will be flat
packed and packaged 3-units per carton. Each bamboo shelf panel will approximate 12.5” in length, 30” in
width, and .6’ in depth.
The applicable subheading for the subject merchandise will be 9403.99.2080, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Other furniture and parts thereof: Parts: Other: Other: Of
cane, osier, bamboo or similar materials: Other.” The general rate of duty will be free.
Sourcing Scenario:
The ruling request outlines an operation wherein in China (1) wooden bamboo reeds will be harvested, (2)
the bamboo reeds are cut into thin strips, dried in a pressurized chamber, and sorted by quality and color (3)
the bamboo reeds are pressed and glued to create thin panels, and (4) multiple thin panels are then pressed
and glued together to create larger rough bamboo blank decks. Metal threaded inserts will be sourced in
Malaysia. The furniture components will be shipped and exported to Vietnam. In Vietnam, polyurethane
wood sealer, wood stain, glue, epoxy resin, and packing materials will be locally sourced. In Vietnam, the
incomplete, unassembled, and unfinished wooden furniture components will undergo manufacture.
Per your submission, in Vietnam, (1) multiple shelf components will be cut from one large Chinese rough
bamboo blank deck, the rough bamboo blank deck will be cut to size, shaped, sanded, and edge profiled
using computer numerical code (CNC) machines, (2) six holes will be drilled using CNC machines and six
metal threaded inserts will be installed, (3) the bamboo panel shelf corners and edges will be hand sanded to
remove rough and uncut areas, (4) the bamboo panel shelf face and reverse will be examined and undergo
additional sanding to remove imperfections, (5) ultraviolet (UV) polyurethane wood sealer will be sprayed
and the bamboo panel shelf will be air cured, (6) a tint coat of brown, dark brown, or black will be applied to
the bamboo panel shelf face and reverse, (7) the bamboo panel shelf face and reverse will have a final topcoat
of polyurethane applied, and (8) if overspray or bubbles are uncovered, repairs and additional polyurethane
will be applied. In Vietnam, the complete, wooden furniture components will be cleaned, packed, labeled,
and then exported to the United States. Photographs of these processes were provided.
Country of Origin:
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).
In the instant case, the individual Chinese and Malaysian components lose their identities during manufacture
and assembly and undergo a substantial transformation in Vietnam to become complete wooden furniture
shelf panel components, thereby, taking on a new name, character, and use. In view of these facts, the
country of origin for the wooden furniture shelf panel components will be Vietnam.
Trade Remedy:
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 Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
9403.99.2080, 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 Dharmendra Lilia at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division