CLA-2-44:OT:RR:NC:N1:130
Mr. John Nourijanian
Armen Cargo Services, Inc.
15036 182nd St.
Springfield Garden, NY 11413
RE: The tariff classification of molded fiberboard door skins from Romania
Dear Mr. Nourijanian:
In your letter, dated February 12, 2019, you requested a tariff classification ruling. Product information and samples were submitted for our review. All samples except one will be returned, as requested. The one sample will be retained for reference.
The product under consideration is molded fiberboard door skin panels, made for use as facings on interior doors. The panels are made from a single, continuous fiberboard sheet that is molded so that the surface replicates the raised-panel shape and appearance of a traditional rail-and-stile door. The outer face is primed and has been embossed with a wood grain texture. The panels measure approximately 3mm in thickness, and are imported in multiple door sizes. You indicate that the panels are made by a process whereby dry wood fiber and resin are mixed and subjected to heat and pressure.
In your letter, you suggest that the panels are classifiable under heading 4418, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Heading 4418 requires that the item be a recognizable article utilized in the construction of a building. The instant panels are utilized in the construction of a door, not a building. Furthermore, the provision for doors in heading 4418, HTSUS, does not provide for parts thereof. Therefore, classification in heading 4418, HTSUS, is precluded. Additionally, the Explanatory Notes to the Harmonized System (ENs) for heading 4411 state that fiberboard remains classified in heading 4411 “whether or not it has been mechanically worked, surface worked, or covered, … and, in addition may be worked to form the shapes provided for in heading 4409, curved, corrugated, perforated…or submitted to any other operation provided it does not give them the character of articles of other headings.” It is thus clear that heading 4411 encompasses a wide range of fiberboard products, including those that have undergone fairly extensive processing. While the instant door skins may have the character of “door parts,” one cannot say that they are outside the contemplated scope of heading 4411, HTSUS.
The manufacturing process you describe – the addition of thermosetting resins to dried wood fibers – is referred to in the ENs as the “dry production process”. The dry production process is indicative of medium density fiberboard (MDF), and the density may generally range from 0.45g/cm3 to 1 g/cm3. While you do not state the density of the panels, it is clear from the manufacturing that they qualify as MDF.
The applicable subheading for the molded fiberboard door skins will be 4411.12.9090, 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 not exceeding 5 mm: Other: Other: Other: Other. The rate of duty will be 3.9 percent ad valorem.
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 on the World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Laurel Duvall at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division