CLA-2-44:S:N:N8:230 803312
Ms. Kaarina Tiainen
Import/Distribution Manager
Plywood & Door Manufacturers Corp.
P.O. Box 1212
Union, NJ 07083
RE: The tariff classification of film faced and printed birch
plywood from Finland
Dear Ms. Tiainen:
In your letter dated September 27, 1994 you requested a
tariff classification ruling.
The ruling was requested on a film faced plywood product
tradenamed Betofilm. A sample piece of the product was
submitted. It consists of nine sheets of alternating birch and
spruce veneers with both outer plies of birch. Each sheet of
veneer is under 6 mm in thickness and the grains of the veneers
run at angles to each other. The plywood is surface covered with
a film coating consisting of 120 gram brown phenol resin. The
coating is applied to the plywood by means of a hot-press
operation in which the resin carried on a film paper liquifies
and impregnates the plywood under heat and pressure. The coating
operation is identical to the one applied to the Wisaform plywood
classified in NY ruling 864976 of August 26, 1991. However, in
addition to this coating, the Betofilm plywood also has 3 cm high
white block printed letters spelling "BETO" and "FILM" throughout
both surfaces.
The sample was forwarded to our Customs Laboratory for an
analysis of the effect of the surface coverings on the grain and
texture of the plywood. The laboratory found that the grain and
texture of the plywood were visible through the brown phenol
resin coating but that the grain and texture of the plywood were
obscured through the additional printed letters.
The applicable subheading for the Betofilm printed and film
faced plywood will be 4412.12.5000, Harmonized Tariff Schedule of
the United States Annotated (HTSUSA), which provides for plywood
consisting solely of sheets of wood, each ply not exceeding 6 mm
in thickness; with at least one outer ply of nonconiferous wood;
other (than 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). The rate of duty will be 8 percent
ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport