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HQ 085227

August 7, 1989

CLA-2 CO:R:I 085227 MBH


TARIFF NO.: 4418.90

Frank Michiels, Esq.
Garvey, Schubert & Barer
1011 Western Avenue
Seattle, Washington 98104-1023

RE: Glue-laminated Timber (glulam)

Dear Mr. Michiels:

This is in reference to your submission dated May 31, 1989, on behalf of Bohemia Inc., with respect to the proper tariff classification of certain glue-laminated timber (glulam) under the Harmonized System.


A sample is submitted. It consists of seven pieces of timber each measuring 12 inches by 3 inches by 1.5 inches. The timbers have been laminated so that the grain of all of the beams is parallel to the length of the member. Glulam is used as a structural product in building construction. Although the lamination process is not described, it is our understanding that an adhesive is applied to bond the faces of the wood under extreme heat and pressure. You state that the normal depth of one glulam ranges from 9 inches to 6 feet and that lengths range from 10 feet to 140 feet. Your client exports glulam to Japan.


Whether the instant merchandise is classifiable as builders' carpentry in heading 44.18 or as plywood, veneered panels and similar laminated wood in heading 44.12.


Heading 44.18 provides for, among other things, builders' joinery and carpentry of wood. The Explanatory Notes, are the official interpretation of the Harmonized System at the international level. The Explanatory Notes to heading 4418 provide as follows:

"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. Laminations of curved members are arranged so that the plane of each lamination is at 90 degrees to the plane of the applied load; thus, laminations of a straight glulam beam are laid flat."

It is clear that the instant merchandise meets the description of glulam in the Explanatory Notes to heading 44.18. Its construction, dimensions, and load bearing capacity identify it as a structural product of this heading.

You indicate that the Government of Japan has been classifying glulam in heading 44.12 for plywood, veneered panels and similar laminated wood. It is clear that the instant product is not plywood or veneered panels. The question presented is whether it may be considered "similar laminated wood".

The Explanatory Notes to heading 44.12 state that similar laminated wood can be divided into two categories: 1) blockboard, laminboard and batten board in which the core is thick and composed of blocks, laths or battens of wood glued together and surfaced with outer plies; and 2) panels in which the wooden core is replaced by other materials such as a layer or layers of particle board, fiber board, wood wage glued together, absestos or cork.

The sample does not meet the description of either of these two types of products since it is neither surfaced with outer plies, nor does it have a material replacing its wooden core. In addition, the Explanatory Notes to 44.12 provide the following exclusion:

However, the heading does not cover massive products such as laminated beams and arches (so-called "glulam" products) (generally heading 44.18).

(Emphasis in original).

It is thus clear that glulam is not classifiable in heading 44.12.


The instant merchandise is classifiable under the provision for builders' joinery and carpentry of wood, including cellular wood panels, assembled parquet panels, shingles and shakes: other, in subheading 4418.90.

We have been advised by the Office of the United States Trade Representative that it is currently examining the appropriate procedure to convey the views of the United States concerning this matter to the Government of Japan.


Harvey B. Fox

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