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NY 864930

JUL 26 1991

CLA-2-94:S:N:N1:233 864930


TARIFF NO.: 9403.90.7000

Ms. Lynne W. Wendt
Sandler, Travis & Rosenberg, P.A.
Attorneys At Law
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1527

RE: The tariff classification of a "drawer system" and plywood panels from Italy.

Dear Ms. Wendt:

In your letter dated July 2, 1991, on behalf of Valendrawers, Inc., North Carolina, you requested a tariff classification ruling.

The furniture items consist of a "drawer system" and plywood lengths. The "drawer system" is a ready-to-assemble prefinished wood drawer system that is made from premium beech hardwood and beech plywood. All components are prefinished in a catalyzed polyurethane and are ready to be assembled. The "drawer system" utilizes chuck and bore technology making for fast, simple and total interchangeability. As imported, the "drawer system" is a complete drawer that is unassembled and ready for assembly.

The plywood panels are beech veneered for manufacturing into drawer sides. The plywood consists solely of sheets of wood, each ply not exceeding 6 mm in thickness. It is prefinished in a catalyzed polyurethane. Valendrawers has imported the boards unmachined (no grooving or borings) and machine groved. The boards are imported in approximately 10 different heights. These boards are imported for sale to original equipment manufacturers, such as cabinet shops.

The applicable subheading for the wood "drawer system" will be 9403.90.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other furniture and parts thereof, parts, of wood.

The rate of duty will be 5.3 percent ad valorem.

We cannot issue a ruling for the plywood panels, both grooved and not grooved. The following additional information is required:

1). The veneer species on both surfaces.

2). A full description and sample showing the finishing with a catalyzed polyurethane.
3). A description of the grooving and a sample. 4). Clarify, the processing done to the grooved plywood after importation (step by step).

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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