RE: The classification, country of origin, and marking of plywood cable reel flanges

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 N365968 October 19, 2026 CLA-44:OT:RR:NC:N5:130 CATEGORY: Classification; Country of Origin; Marking Mr. Georgiy Aiozba Iberiaholz LTD. General Mazniashvili St. Batumi, 6010 Georgia RE: The classification, country of origin, and marking of plywood cable reel flanges Dear Mr. Aiozba: In your letter, dated October 13, 2026, you requested a classification, country of origin, and marking ruling for plywood cable reel flanges. Product information and photos were submitted for our review. The product under consideration is cable reel flanges manufactured from plywood. The flanges are circular and range in diameter and thickness. They are drilled in the center for the central axle and precision cut and drilled around the center for functional holes. The flanges form the ends of a cable reel. In your letter, you question whether the cable reel flanges are classifiable in headings 4412 and 4415, Harmonized Tariff Schedule of the United States (HTSUS). The flanges are not classifiable in heading 4415, HTSUS, as the heading provides only for complete cable drums and not parts thereof. The flanges are not classifiable in heading 4412, HTSUS, because, while Note 4 to Chapter 44 provides that plywood of 4412 can be worked: 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 plywood must not take on the character of articles of other headings. The cutting to circular shape and drilling of axle and other functional holes/openings renders a product that is recognizable as a cable reel flange. Therefore, classification in heading 4412, HTSUS, is precluded. The applicable subheading for the plywood cable reel flanges will be 4421.99.9880, HTSUS, which provides for Other articles of wood: Other: Other: Other: Other Other. The general rate of duty will be 3.3 percent ad valorem. You outline a scenario wherein birch plywood from Kazakhstan is imported into Georgia, where it is cut to shape and precision drilled for the central axle and functional holes, edge-finished, and packaged. The flanges will be shipped to the United States alone, with no other cable reel components. 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). As noted above, the cutting to shape and drilling dedicate the plywood for use specifically as cable reel flanges. This substantial transformation occurs in Georgia, therefore Georgia is the country of origin. The cable reel flanges can be marked “Made in Georgia” or “Product of Georgia” as appropriate. 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