CLA-2-44:OT:RR:NC:N5:130
Mr. Cesar Cisneros
1200 Isabella Grace St.
Weslaco, TX 78599
RE: The tariff classification of wood products from multiple countries
Dear Mr. Cisneros:
In your letter, dated November 14, 2025, you requested a binding tariff classification and country of origin
ruling on behalf of your client, Rockwood International, LLC. The request was returned to you for additional
information, which was received by this office on December 19, 2025. The ruling addressed medium density
fiberboard (MDF) and plywood components that will be imported for the manufacture of cabinet parts.
Product information and photos were submitted for our review.
The first product under consideration is MDF sheets. The sheets are rectangular and not worked with any
shaping, edge-banding, drilling or other manufacturing. The fiberboard consists of wood fiber processed by
the dry manufacturing process, where dry fiber is mixed with resin and subjected to heat and high pressure.
As such it meets the terms of MDF, as outlined in the Explanatory Notes to the Harmonized System (ENs)
for heading 4411. The dimensions range from 7.8 to 20.7 inches in width, 11.8 to 49.2 inches in length, and
the panels are approximately 3/4 inch in thickness. You have provided photos of two different products, one
that is unfinished MDF, and one that is MDF surfaced with a white laminate. You indicate that the MDF
sheets are wholly made in Mexico.
The applicable subheading for the unfinished MDF sheets will be 4411.14.1000, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for Fiberboard of wood or other ligneous materials, whether
or not bonded with resins or other organic substances: Medium density fiberboard (MDF): Of a thickness
exceeding 9 mm: Not mechanically worked or surface covered. The general rate of duty will be free.
The applicable subheading for the MDF sheets surfaced with white laminate will be 4411.14.9090, HTSUS,
which provides for Fiberboard of wood or other ligneous materials, whether or not bonded with resins or
other organic substances: Medium density fiberboard (MDF): Of a thickness exceeding 9 mm: Other: Other:
Other: Other. The general rate of duty will be 3.9 percent ad valorem.
The second product is plywood sheets. The sheets measure 12mm and 18mm in thickness. The face and
back consist of okoume wood (Aucoumea spp., a tropical wood) and the core veneers are maple. Each veneer
is under 2mm in thickness, and the grain of each veneer layer is oriented at 90 degrees to the adjacent layers.
The panels range from 12 to 42 inches in width and are 96 inches in length. The panels are surface-covered
with an opaque paper which obscures the grain of the wood. You indicate that the panels are manufactured
in Vietnam.
The panels meet the definition of plywood set forth in the ENs to heading 4412. They are panels “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.” Plywood is specifically provided for under heading 4412 of the
HTSUS, therefore, it is classifiable therein.
The applicable subheading for the plywood sheets will be 4412.31.6100, 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: With at least one outer ply of tropical wood:
Other: With at least one outer ply of the following tropical woods: Dark Red Meranti, Light Red Meranti,
White Lauan, Sipo, Limba, Okoumé, Obeche, Acajou d'Afrique, Sapelli, Virola, Mahogany, Palissandre de
Para, Palissandre de Rio or Palissandre de Rose. The general rate of duty is 8 percent ad valorem.
The third product under consideration is identified as “I-beam structural supports”. The product at time of
importation into the United States is, in fact, scrap plywood. The pieces are 3 to 5.2 inches in width, random
lengths, and 1/2 inch in thickness. The plywood pieces have a face and back of okoume wood, but do not
have a surface covering. The plywood pieces meet the definition of plywood as set forth in the ENs to
heading 4412 and thus are classified in heading 4412. You indicate that the plywood is manufactured in
Vietnam and the scrap is generated in Mexico.
The applicable subheading for the “I-beam structural supports” will be 4412.31.4869, 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: With at least one outer ply of
tropical wood: 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: With at least one outer ply of the following
tropical woods: Dark Red Meranti, Light Red Meranti, White Lauan, Sipo, Limba, Okoumé, Obeche, Acajou
d'Afrique, Sapelli, Virola, Mahogany, Palissandre de Para, Palissandre de Rio or Palissandre de Rose: Other:
Other: Not surface covered: Other. The general rate of duty is 8 percent ad valorem.
As the MDF sheets are fully manufactured in Mexico, the country of origin at time of importation is Mexico.
The plywood has been manufactured in Vietnam. It then goes to Mexico where the opaque surface covering
is applied to its face and back. The application of an opaque surface covering is not a substantial
transformation of the plywood. Therefore, the country of origin at the time of importation into the United
States will be Vietnam.
The “I-beam structural supports” are scrap of plywood that was manufactured in Vietnam. The work in
Mexico that reduced the plywood to smaller pieces is not a substantial transformation of the plywood.
Therefore, the country of origin of the “I-beam structural supports” at time of importation into the United
States will be Vietnam.
You appear to want to determine if the goods, after further manufacturing in the United States, are products
of the United States. Customs and Border Protection’s jurisdiction does not extend to products manufactured
in the United States; CBP governs goods in their condition as imported into the United States. If you wish to
determine whether the goods are identifiable as “Made in the United States”, please contact the Federal Trade
Commission at:
Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580
Telephone: (202) 326-2222
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
Hardwood plywood from Vietnam may be subject to antidumping duties and countervailing duties
(AD/CVD) for hardwood plywood from Vietnam (A552-851, C552-852). Hardwood plywood from Vietnam
is currently under investigation, with preliminary results due February 25, 2026. Written decisions regarding
the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade
Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin
rulings issued by Customs and Border Protection (CBP). General information regarding the ITA and
AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s
“Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf
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