CLA-2-44:OT:RR:NC:N5:130
Mr. Matthew Anderson
Charter Brokerage LLC
22762 Westheimer Parkway
Katy, TX 77450
RE: The tariff classification of insulated oriented strand board from Canada
Dear Mr. Anderson:
In your letter, dated October 22, 2025, you requested a binding tariff classification ruling on behalf of your
client, BTRBoard, Inc. The classification was requested for oriented strand board (OSB) with a layer of
insulation. Product information and pictures were submitted for our review.
The product under consideration is BTRBoard OSB. This product consists of a 7/16” layer of OSB adhered
to a 1 3/16” layer of polyurethane (PU) foam. The PU foam has a thin layer of fiberglass affixed to it for
protection during shipping. The OSB is used as sheathing in buildings, with the PU foam acting as
insulation. The OSB is used as OSB would typically be used, but with improved insulation properties.
The Explanatory Notes to the Harmonized System for heading 4410 provide that “(t)he products of this
heading remain classified herein whether or not they have been…coated or covered (e.g., with textile fabric,
plastics, paint, paper or metal) or submitted to any other operation, provided these operations do not thereby
give such products the essential character of articles of other headings.” Insulation is a covering generally
considered to enhance products but not change their essential character.
The applicable subheading for the BTRBoard OSB will be 4410.12.0020, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Particle board, oriented strand board (OSB) and similar board
(for example, waferboard) of wood or other ligneous materials, whether or not agglomerated with resins or
other organic binding substances: Of wood: Oriented strand board: Other. The general rate of duty will be
free.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty. At
the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to
subheading 4410.12.0020, 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 9903.01.10. If your product is entered
duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to
subheading 4410.12.0020, 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 Canada 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., 9903.01.26, in addition to subheading 4410.12.0020, 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division