RE: The country of origin of plywood

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365961 October 16, 2026 MAR-44:OT:RR:NC:N5:130 CATEGORY: Country of Origin Mr. Jonas Israel McCorry & Co Limited Unit C, 17/F, United Centre, 95 Queensway, Admiralty Hong Kong, HK 91 China RE: The country of origin of plywood Dear Mr. Israel: In your letter, dated October 12, 2026, you requested a country of origin ruling for plywood. Product information was submitted for our review. The product under consideration is plywood. You outline a scenario wherein plywood cores consisting of three to seven plies (no ply exceeding 6mm in thickness and grains of plies oriented at 90-degree angles) are manufactured from tropical wood in Malaysia. The cores are then exported to Indonesia, where they are laminated with outer plies of hardwoods including maple, poplar, oak, and birch woods from the United States, Canada, Latvia, and China. The finished panels will be exported from Indonesia to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). The plywood cores meet the definition of “plywood” as set forth in the Explanatory Notes to the Harmonized System for heading 4412: “plywood” is panels “consisting of three or more sheets of wood glued and pressed one on the other and generally disposed so that the grains of successive layers are at an angle.” The cores consist of at least three layers and are laminated with the grains of the layers being oriented at an angle to the adjacent layers. When the face and back are laminated onto the panels, the resulting product still meets the definition of “plywood”. Therefore, the substantial transformation occurs when the core veneers are laminated into a core panel. This transformation takes place in Malaysia, and therefore, Malaysia is the country of origin. Your product may be subject to antidumping or countervailing duties for hardwood plywood. To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide to seeking a scope ruling can be found at https://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD investigations at the United States International Trade Commission can be viewed on its website at http://www.usitc.gov. Additionally, messages sent by Commerce to CBP regarding AD/CVD cash deposits and liquidation can be searched using ACE or CBP’s search tool at https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division