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July 15, 1999

CLA-2-44:RR:NC:SP:230 D83156


TARIFF NO.: 4415.20.8000

Mr. Mike Leahy
A.N. Deringer, Inc.
173 W. Service Road
Champlain, NY 12919

RE: The tariff classification of unassembled wooden pallets from Canada.

Dear Mr. Leahy:

In your letter dated September 30, 1998, on behalf of L.C.N. Inc. (St. Felix De Kingsey, Quebec, Canada), you requested a tariff classification ruling. We regret that our response was delayed by the U.S Customs Service’s review of the classification of lumber products.

The items in question are unassembled wooden pallets (load-board products) of the kind commonly used as portable platforms for cargo handling, storage, etc. Each pallet consists of 15 pieces of spruce lumber which have been precut to specific sizes, ready for assembly without further manufacturing or milling. In order to be ready for use as pallets following importation, the pieces merely have to be assembled on a nailing machine.

The specifications of the 15 pieces are as follows:

Qty. Thickness Width Length Description
2 3/4" 5 1/2" 40" Face boards to be placed at each end 5 3/4" 3 1/2" 40" Face boards
3 1 1/2" 3 1/2" 48" Stringers (notched boards) 2 3/4" 5 1/2" 40" Chamfered bottom deck boards to be placed at each end 3 3/4" 3 1/2" 40" Chamfered bottom deck boards

You state that each shipment will contain the proper quantity/combination of pieces to make a given number of pallets. In light of that circumstance, and in accordance with General Rule of Interpretation 2(a) of the Harmonized Tariff Schedule of the United States (HTS), the imported goods will be classifiable as pallets despite their unassembled condition at the time of entry.

The applicable subheading for the unassembled wooden pallets will be 4415.20.8000, HTS, which provides for pallets, box-pallets, other load boards and pallet collars of wood: other than containers designed for use in the harvesting of fruits and vegetables. The general rate of duty will be 10.7%.

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

In the event it is determined that the imported goods are not being manufactured and presented exactly as described in this ruling, the ruling will not be applicable to those goods. You should also be aware that the facts described in the foregoing ruling may be subject to periodic verification by the Customs Service.

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 212-637-7009.


Robert B. Swierupski

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