The tariff classification of blank plywood boards from China

N260043 January 7, 2015 CLA-2-44:OT:RR:NC:2:230 CATEGORY: Classification TARIFF NO.: 4412.32.3185 Mr. Kevin W. Stewart DJS International Services, Inc. 4215 Gateway Drive Suite 100 Colleyville, TX 76034 RE: The tariff classification of blank plywood boards from China Dear Mr. Stewart: In your letter dated October 28, 2014, you requested a tariff classification ruling on behalf of your client, Soy Group, Inc. The ruling was requested on blank plywood boards. Two representative samples, one in the condition as imported and one in the condition after being further worked after importation, were submitted for our review. The samples will be returned to you, as requested. The sample of the board in its imported condition measures approximately 19 ½” (L) x 4” (W) x 32mm in thickness, and is constructed of 7 plies of basswood tilia, a non-coniferous wood.  No ply exceeds 6mm in thickness, and the grain of each ply runs at an angle to that of the successive ply.  The boards are pre-cut and the corners have been rounded.  The boards are coated with a clear material that does not obscure the grain of the wood.  In your letter, you state that, after importation, the blank boards will be manufactured into puzzles.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 The boards meet the definition of plywood of heading 4412, Harmonized Tariff Schedule of the United States (HTSUS).Legal Note 2 of Chapter 44, HTSUS, states that products of heading 4410, 4411 or 4412 may be worked to form the shapes provided for in respect of the articles of heading 4409, curved, corrugated, perforated, cut or formed to shapes other than square or rectangular or submitted to any other operation provided it does not give them the character of articles of other headings. The curving of the boards’ corners does not give the boards the character of articles of another heading. The applicable subheading for the blank plywood boards will be 4412.32.3185, HTSUS, which provides for Plywood, veneered panels and similar laminated wood: Other plywood, consisting solely of sheets of wood, each ply not exceeding 6 mm in thickness: Other, with at least one outer ply of nonconiferous wood: 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:Other:Other:Other The rate of duty will be 8 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 World Wide Web at http://www.usitc.gov/tata/hts/. 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 LAUREL.DUVALL@CBP.DHS.GOV. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division