The tariff classification of film faced and printed birch plywood from Finland

NY 803312 December 28, 1994 CLA-2-44:S:N:N8:230 803312 CATEGORY: Classification TARIFF NO.: 4412.12.5000 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