CLA-2-44:OT:RR:NC:N5:130

Mr. Paul Zhu
Brooklyn Plywood Ltd.
855 39th Street
Brooklyn, NY 11232

RE: The classification of melamine- and HDF-overlaid edge-glued lumber from Indonesia

Dear Mr. Zhu:

In your letter, dated March 23, 2026, you requested a binding classification ruling on edge-glued lumber faced with melamine-impregnated paper and high-density fiberboard (HDF). Product information and a sample were provided for our review.

The product under consideration is approximately 19mm in thickness. The panel is constructed of edge-glued lumber consisting of jabon, gmelina, and racuk (padauk) (all tropical woods). The edge-glued lumber has been overlaid on both sides with a 2mm-thick sheet of HDF and a layer of opaque melamine-impregnated paper. The edge-glued lumber is not surfaced with veneers beneath the HDF and paper.

The classification of edge-glued lumber is impacted by being overlaid with HDF and melamine-impregnated paper. The Explanatory Notes to the Harmonized System for Chapter 44 instruct that

…the classification of wood is not affected by treatment necessary for its preservation, such as seasoning, superficial charring, priming and stopping, or impregnation with creosote or other wood preservatives (e.g., coal tar, pentachlorophenol (ISO), chromated copper arsenate or ammoniacal copper arsenate); nor is it affected by reason of being painted, stained or varnished.

Since the edge-glued lumber is treated beyond the limitations of this instruction, the product is not classified as edge-glued lumber.

The applicable subheading for the edge-glued lumber faced with HDF and melamine-impregnated paper will be 4421.99.9880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other articles of wood: Other: Other: Other: Other: Other. The general rate of duty will be 3.3 percent ad valorem. 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 the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.

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 P. Forkan
Director
National Commodity Specialist Division