The tariff classification of wood drawer components from China

N321073 September 9, 2021 CLA-2-44:OT:RR:NC:N4:434 CATEGORY: Classification TARIFF NO.: 4421.99.9780; 9903.88.03 Mr. Bob Zou Comtrad Strategic Sourcing, Inc. 5106 Timberlea Blvd. Mississauga, Ontario L4W 2S5 CANADA RE: The tariff classification of wood drawer components from China Dear Mr. Zou: In your letter, dated August 16, 2021, you requested a binding classification ruling. The ruling was requested on wood boards to be used as drawer components. Product information and photos were provided for our review. The items under consideration are white poplar edge-glued boards cut with a continuous groove along their length. They are UV-coated. The boards come in various dimensions, measuring 72” to 96” in length, 4” to 12” in width and 3/8” to 5/8” in thickness. Per your submission, after importation they will be used in the construction of cabinet drawers. To use as such, the U.S. customer must cut the boards to length and then further fabricate as per requirements of the specific drawers, (e.g., cutting different types of joints) and add any final finish that is required.  The boards 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 applicable subheading for the edge-glued boards 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. The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD).  Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP).  You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”).  For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at https://www.usitc.gov (click on “Antidumping and Countervailing Duty” under “Popular Topics” at the top of the screen), and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4421.99.9780, HTSUS, unless specifically excluded, are subject to an additional 25% percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, 9903.88.03, in addition to subheading 4421.99.9780, HTSUS, listed above.   The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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 above ruling, contact National Import Specialist Charlene Miller at charlene.s.miller@cbp.dhs.gov.Sincerely, Steven A. Mack Director National Commodity Specialist Division