CLA-2-44:OT:RR:NC:N5:130
Ms. Cassie Ablamowicz
Grey Woods Company
5101 Dundas Street West
Toronto, ON M9A 5G8
Canada
RE: The tariff classification, country of origin, and applicable trade programs for personalized plywood
tags
Dear Ms. Ablamowicz:
In your letter, dated September 16, 2026, you requested a binding tariff classification, country of origin, and
applicability of trade programs ruling on personalized plywood tags. Product information and photos were
submitted for our review.
The products under consideration are multiple styles of personalized name or gift tags. The tags are made
from 3-layer 1/8-inch Baltic birch plywood. They are cut-to-shape, drilled with a hole, and stained and
painted with an individual’s name in chalk paint. The tags may be cut in multiple shapes, like a classic gift
tag shape, a stylized gift tag shape, or an animal shape, like a bunny. The tag is threaded with twine to attach
it to another item, such as a gift or a basket, and some tag twine is threaded with wood beads for additional
decoration.
Because the tags are utilitarian and not simply ornamental, they are not classified as ornaments of wood. As
you suggest, the correct classification is in heading 4421, Harmonized Tariff Schedule of the United States
(HTSUS), as other articles of wood (code and duty rate below.).
In your letter, you describe a scenario wherein birch plywood originating in Russia is imported into Canada.
In Canada, you cut and drill the plywood into tag shapes, stain it, paint it, and attach twine to it, and perhaps
attach wooden beads where appropriate.
The United States-Mexico-Canada Agreement (USMCA) was signed by the Governments of the United
States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with
the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14
(19 U.S.C. § 4511(a)). General Note (“GN”) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth
the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b)
states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a “good originating in the territory of a USMCA country” only if—
the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials;
the good is a good produced entirely in the territory of one or more USMCA countries using
non-originating materials, if the good satisfies all applicable requirements set forth in this note
(including the provisions of subdivision (o));
Subdivision (o) states that, in order to be subject to USMCA, the manufacturing in a USMCA country must
result in “A change to headings 4401 through 4421 from any other heading, including another heading within
that group.” Since the manufacturing results in a change from heading 4412 (plywood) to 4421 (other
articles), this rule is met. Therefore, the plywood tags qualify for USMCA preferential treatment. The
country of origin for duty purposes is Canada.
The "country of origin" is defined in Title 19, Code of Federal Regulations (CFR), Section 134.1(b) as:
…the country of manufacture, production, or growth of any article of foreign origin entering the
United States. Further work or material added to an article in another country must effect a substantial
transformation in order to render such other country the 'country of origin' within the meaning of this
part; however, for a good of a NAFTA or USMCA country, the marking rules set forth in part 102 of
this chapter (hereinafter referred to as the part 102 Rules) will determine the country of origin.
Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other
USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in
§§ 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to
goods imported from Canada and Mexico.
Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking
purposes, with the exception of textile goods which are subject to the provisions of 19 C.F.R. § 102.21. See
19 C.F.R. § 102.11. 19 CFR Part 102.11(a) provides that the country of origin of a good is the country in
which:
(1) The good is wholly obtained or produced;
(2) The good is produced exclusively from domestic materials; or
(3) Each foreign material incorporated in that good undergoes an applicable change in tariff
classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and
all other applicable requirements of these rules are satisfied.
The personalized plywood tags are neither “wholly obtained or produced” nor “produced exclusively from
domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of
origin of the personalized plywood tags and paragraph (a)(3) must be applied next to determine the origin of
the finished article. Section 102.20 (19 CFR 102.20) sets forth the applicable tariff change rules that address
the current scenario. Goods classified in heading 4421 must undergo a change as follows: “A change to any
other good of heading 4413 through 4421 from any other heading, including another heading within that
group.” The unfinished plywood from Russia, classifiable in heading 4412, is transformed in Canada by
cutting to shape, painting, staining, and finishing into other articles of wood in heading 4421. Therefore, the
tariff shift rule has been met. The country of origin for marking purposes is Canada.
The applicable subheading for the plywood tags will be 4421.99.9880, HTSUS, which provides for Other
articles of wood: Other: Other: Other: Other: Other. The general rate of duty will be free.
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