CLA-2-44:OT:RR:NC:N5:130
Mr. Fernando Zertuche
Danzer Veneer Americas, Inc.
119 AID Dr.
Darlington, PA 16115
RE: The classification and country of origin of wood veneers
Dear Mr. Zertuche:
In your letter, dated February 16, 2026, you requested a binding classification and country of origin ruling on
wood veneers. Product information and photos were provided for our review.
The product under consideration is Danzer LINEA veneers in oak and walnut. The veneers will measure
approximately 0.55 – 0.65 mm in thickness. The LINEA veneers are of similar construction to reconstituted
veneer. Many veneers are laminated together into a block and sliced to form a wood veneer with a linear
structure and pattern. The veneers that will be bonded together are all American white oak (Quercus alba, a
non-coniferous wood) or American walnut (Juglans nigra, a non-coniferous wood) of a thickness of
0.50-0.51mm. They will not be mixed with other species of wood or dyed, coated, or impregnated. You do
not indicate that these veneers will be spliced. The finished veneers will measure approximately 2 feet wide
by 8, 10, or 12 feet long. You do, however, indicate that the veneers may be subjected to an additional
splicing operation that will result in veneers measuring approximately 4 feet wide by 8 or 10 feet long.
The applicable subheading for the unspliced LINEA oak veneer will be 4408.90.0181, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Sheets for veneering (including those obtained
by slicing laminated wood), for plywood or for similar laminated wood and other wood, sawn lengthwise,
sliced or peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness not exceeding 6 mm:
Other: Other: Oak (Quercus spp.): Other. The general rate of duty will be free.
The applicable subheading for the unspliced LINEA walnut veneer will be 4418.90.0187, HTSUS, which
provides for Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for
similar laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded,
spliced or end-jointed, of a thickness not exceeding 6 mm: Other: Other: Walnut (Juglans spp.). The general
rate of duty will be free.
The applicable subheading for spliced LINEA oak veneer will be 4408.90.0137, HTSUS, which provides for
Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for similar
laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or
end-jointed, of a thickness not exceeding 6 mm: Other: Spliced or end-jointed: Oak (Quercus spp.): Other.
The general rate of duty will be free.
The applicable subheading for spliced LINEA walnut veneer will be 4408.90.0145, HTSUS, which provides
for Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for similar
laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or
end-jointed, of a thickness not exceeding 6 mm: Other: Spliced or end-jointed: Walnut (Juglans spp.). The
general rate of duty will be free.
For origin, you outline a scenario wherein US-origin, whole wood veneers are shipped to the Czech Republic
where they are glued and laminated into a block under heat and high pressure. Then the blocks are sliced into
thin veneers before being shipped back to the US. You also note that the veneers may be shipped to Canada
for splicing before returning to the US.
When determining the country of origin for purposes of applying duty rates, 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).
The US whole wood veneers undergo two substantial transformations in the Czech Republic. First, they are
laminated together to form a veneered block, and second, the veneered block is sliced to form veneers. As a
result of the manufacturing, the country of origin is the Czech Republic. If the veneers are shipped to Canada
to be spliced, no substantial transformation occurs in Canada and the country of origin is still the Czech
Republic.
The 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/.
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.
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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division