CLA-2-44:OT:RR:NC:N1:130
Mr. Daniel Weir
Weir Plywood and Door LLC
219 N. First Street
Pacific, MO 63069
RE: The tariff classification of wood drawer components from Vietnam
Dear Mr. Weir:
In your letter, dated July 8, 2021, you requested a binding tariff classification ruling. The ruling was requested on wood drawer components. Product information and photos were provided for our review.
The first item is “short” poplar (a non-coniferous wood) drawer components. The components are made from wood boards that are surfaced on four sides (“S4S”) and measure 18” or 21” in rough-cut length by 2” or 10” in width by 5/8” or 3/4" in thickness. The wood may be either solid or edge-glued. These boards will be shaped with radius-cut corners on one edge, and with a 1/4" wide by 1/4" deep groove on the panel face, 1/2" from the opposite edge. The shaping runs the length of the panel, parallel to the grain. The length is then precision-trimmed to customer specification. The boards may be UV-coated or unfinished. After importation, the customer will further process the components, e.g., by dovetailing and/or finishing.
The second item is “long”, S4S poplar drawer components that measure 8’ in length by 2” or 10” in width by 5/8” or 3/4" in thickness. These boards are edge-glued, finger-jointed, and UV-coated. They will be shaped, as above, with radius-cut corners and a groove. After importation, the customer will cut the panels to length and dovetail them, as necessary.
The panels are not ready for assembly as furniture components at time of importation. Each is continuously shaped throughout its length. While continuously shaped wood is provided for in heading 4409, Harmonized Tariff Schedule of the United States (HTSUS), edge-gluing and UV-coating preclude classification therein. The language of heading 4409 provides only for end-jointing of wood, not edge-joining. The Explanatory Notes to the Harmonized System (ENs) provide that goods of heading 4409 cannot be surface-treated beyond paint, stain, or varnish; UV coating is a treatment beyond paint, stain, or varnish. Because of the shaping, the panels also do not constitute edge-glued lumber.
The short panels are divided into four sub-groups: solid wood panels that are unfinished, solid wood panels that are UV-coated, edge-glued panels that are unfinished, and edge-glued panels that are UV-coated.
The applicable subheading for the solid wood short panels that are unfinished will be 4409.29.9100, HTSUS, which provides for Wood (including strips and friezes for parquet flooring, not assembled) continuously shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, molded, rounded or the like) along any of its edges, ends or faces, whether or not planed, sanded or end-jointed: Nonconiferous: Other: Other: Other. The rate of duty will be free.
The applicable subheading for the solid wood short panels that are UV-coated and/or edge-glued will be 4421.99.9780, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other: Other. The rate of duty will be 3.3 percent ad valorem.
The applicable subheading for the long panels will be 4421.99.9780, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other: Other. The rate of duty will be 3.3 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