CLA-2-44:OT:RR:NC:N5:130
Ms. Anita Woolslager
Lisa Ragan Customs Brokerage
327 West Taylor Street Suite A
Griffin, GA 30223
RE: The tariff classification of multilayer wood flooring from Vietnam
Dear Ms. Woolslager:
In your letter, dated September 10, 2025, you requested a binding tariff classification ruling on behalf of your
client, LW Mountain Import, Inc. The ruling was returned to you for additional information, which was
received by this office on October 2, 2025. The ruling request was for multilayer wood flooring. Product
information and a sample were submitted for our review.
The product under consideration is a multilayer wood flooring panel consisting of 7 plies. We note that the
sample panel differs from the description on your documents. The classification herein will be based on the
physical sample. The flooring panel measures 14mm in thickness and is 5” wide. The panels will be
imported in random lengths. You state that the face ply is European oak (a non-coniferous wood), and the
substrate is eucalyptus and acacia. It appears that the back ply is eucalyptus (a non-coniferous wood). The
face ply measures 3.4mm in thickness. The grain of each ply runs at a 90-degree angle to those of the
adjacent plies. The face ply is coated with a stain that does not obscure the grain of the wood.
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. Plywood is specifically
provided for in heading 4412 of the HTSUS.
The applicable subheading for the multilayer wood flooring panel will be 4412.33.3225, HTSUS, which
provides for Plywood, veneered panels and similar laminated wood: Other plywood consisting solely of
sheets of wood (other than bamboo), each ply not exceeding 6 mm in thickness: Other, with at least one outer
ply of nonconiferous wood of the species alder (Alnus spp.), ash (Fraxinus spp.), beech (Fagus spp.), birch
(Betula spp.), cherry (Prunus spp.), chestnut (Castanea spp.), elm (Ulmus spp.), eucalyptus (Eucalyptus spp.),
hickory (Carya spp.), horse chestnut (Aesculus spp.), lime (Tilia spp.), maple (Acer spp.), oak (Quercus spp.),
plane tree (Platanus spp.), poplar and aspen (Populus spp.), robinia (Robinia spp.), tulipwood (Liriodendron
spp.) or walnut (Juglans spp.): 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 general
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 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
4412.33.3225, HTSUS, listed above.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division