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HQ 088284

March 27, 1991

CLA-2 CO:R:C:T 088284 CRS


TARIFF NO.: 4418.90.4090

Mr. Dennis L. Holman
Assistant Operations Manager
Norman G. Jensen, Inc.
P.O. Box 1450
Blaine, WA 98230

RE: Parallam PSL; parallel strand lumber; builders' joinery and carpentry of wood. Parallam PSL is not lumber for the purposes of subheading 9905.44.10.

Dear Mr. Holman:

This is in reply to your letter of October 23, 1990, to our Blaine, Washington office, on behalf of your client, MacMillan Bloedel, Ltd., concerning the classification of Parallel Strand Lumber (PSL) under the Harmonized Tariff Schedule of the United Stated Annotated (HTSUSA). A further submission was made by MacMillan Bloedel in letters by dated February 20, 1991, and February 22, 1991. A sample was provided.


The article in question is a reconstituted wood product manufactured in Canada and is known commercially as Parallam PSL, a trademark of MacMillan Bloedel, Ltd. Parallam is manufactured by peeling Douglas Fir or Southern Pine logs into veneer sheets. The sheets are clipped into strands up to 8 inches in length and 1/8 inch in thickness, and then bonded under pressure with an adhesive such as phenol formaldehyde. Parallam is available in cross sections up to 12 inches by 24 inches and in lengths up to 66 feet.

In your letter of February 20th you stated that some Parallam PSL products are chemically treated with chromated copper arsenate (CCA) to protect against weather and insects. The CCA treatment is accomplished through the use of pressure which forces the chemical substance into the wood. You have stated that this treatment conforms to the standard specification for pressure treated lumber set forth in ASTM D 1760.


Whether Parallam PSL is classifiable as other builders' joinery and carpentry of wood of subheading 4418.90.40, HTSUSA.

If classifiable in subheading 4418.90.40, whether Parallam PSL is eligible for duty free treatment under subheading 9905.44.10, Subchapter V, Chapter 99, HTSUSA.


Heading 4418, HTSUSA, provides for, inter alia, builders' joinery and carpentry of wood. The Explanatory Notes (EN), while not legally binding, constitute the official interpretation of the Harmonized System at the international level (four and six digits). EN 44.18, 636-637, provides in pertinent part:

The term "joinery" applies more particularly to builders' fittings (such as doors, windows, shutters, stairs, door or window frames), whereas the term "carpentry" refers to woodwork (such as beams, rafters and wood struts) used for structural purposes in scaffoldings, arch supports, etc., ....

Builders' carpentry also includes glue-laminated timber (glulam), which is a structural timber product obtained by gluing together a number of wood laminations having their grain essentially parallel....

The product in question is a structural timber product obtained by laminating plywood strands with an adhesive and is used to make articles such as beams and arch supports. It is similar to, and is a substitute for, glulam. It is therefore classifiable in heading 4418, HTSUSA, specifically, in subheading 4418.90.40, HTSUSA. See Headquarters Ruling Letter (HRL) 086256 dated January 23, 1990, on the classification of laminated veneer lumber.

Subheading 9905.44.10, Subchapter V, Chapter 99, HTSUSA, extends duty free treatment to certain wood products, provided they qualify as goods originating in the territory of Canada pursuant to General Note 3(c)(vii), HTSUSA. The subheading states as follows:

Pressure treated lumber, finger-jointed builders' joinery, and edge-glued lumber (provided for in subheading 4418.90.40) ....

This includes builders' joinery and carpentry of pressure treated lumber. HRL 087616 dated August 20, 1990. The term "lumber" is not defined by the HTSUSA, however. As a general matter, the term refers to: timber or logs that have been prepared for market; the product of a saw and planing mill not further manufactured; a manufactured product derived from a log in a sawmill. See Webster's Third New International Dictionary, 1986, 1345; Wood Handbook: Wood as an Engineering Material, U.S. Dept. Ag., 1987, G-6; McBarron, Dana's Lumber Dictionary and Handbook, 1986, 31. In HRL 087616 we stated in pertinent part:

Lumber, within the HTSUSA, is unfinished wood of all types that has been sawn, chipped, sliced or peeled....

Parallam PSL is not an unfinished sawn, chipped, sliced or peeled wood. It is a highly engineered wood product; accordingly, it is not lumber for the purposes of subheading 9905.44.10.


If not pressure treated, Parallam PSL is classifiable in subheading 4418.90.4090, HTSUSA, under the provision for builders' joinery and carpentry of wood, ..., other, other, and is dutiable at the rate of 3.5 percent ad valorem.

Due to the changeable nature of the statistical annotation (the ninth and tenth digits of the classification) and the restraint (quota/visa) categories, you should contact your local Customs office prior to importation of this merchandise to determine the current status of any import restraints or requirements.


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