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NY C88981

July 2, 1998

CLA-2-44:RR:NC:SP:230 C88981


TARIFF NO.: 4408.90.0080; 4412.29.5500

Ms. Marcia A. Cant

Timber Products Company

P.O. Box 381767

Germantown, TN 38183-1767

RE: The tariff classification of bamboo panels and veneer sheets from China.

Dear Ms. Cant:

In your undated letter received here on June 11, 1998, you requested a tariff classification ruling. Several small samples of bamboo panels (to be imported in 3' x 6', 3' x 8' or similar sizes) and one sample of bamboo veneer were submitted and will be retained for reference. All of the items are intended for use in the manufacture of furniture, cabinetry, doors, etc. Some of the panels may also be used in the production of moldings and flooring.

The sample of "Plyboo Veneer" is a very thin, continuous sheet of bamboo. Its thickness is approximately 0.4 mm. The sample piece is about 16 inches wide and appears to have been peeled from bamboo cane.

The applicable subheading for the "Plyboo Veneer" will be 4408.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for other (than certain enumerated) veneer sheets and sheets for plywood (whether or not spliced)...of a thickness not exceeding 6 mm: not reinforced or backed. The rate of duty will be free.

The sample of "Plyboo MDF" is a laminated panel consisting of three layers: an 18-mm-thick medium density fiberboard core sandwiched between 4 1/2-mm-thick outer layers made of edge-glued strips of bamboo. The grain of all the bamboo strips runs in the same direction.

The two-ply versions of the samples identified as "Plyboo Panels" consist of two layers of bamboo (each about 5 mm thick) which have been laminated together. Each layer is composed of edge-glued strips of bamboo. The grain of all the strips runs in the same direction. One sample is "natural," while the other has been stained to a darker color.

The applicable subheading for the "Plyboo MDF" and the two-
ply "Plyboo Panels" will be 4412.29.5500, HTS, which provides for other (than certain enumerated) veneered panels and similar laminated wood, with at least one outer ply of nonconiferous wood. The rate of duty will be 0.8%.

The one-ply versions of the samples identified as "Plyboo Panels" appear to consist of a single layer of bamboo strips which have been edge-glued together. One of these samples ("natural") is about 3 1/2 mm thick, while the other (stained) is about 5 mm thick. Your inquiry does not provide sufficient information for us to rule on these items. If you wish to pursue the matter, please submit a detailed, step-by-step explanation of the manufacturing process.

With regard to your additional questions, please be advised that none of the merchandise discussed in this letter is currently subject to quota/visa requirements or anti-dumping/ countervailing duties. However, one or more of the items may be subject to requirements administered by the U.S. Department of Agriculture. For further information, you may contact that agency directly at the following location:



4700 River Road, Unit 136

Riverdale, MD 20737-1236

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Paul Garretto at 212-466-5779.


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