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NY G82375

October 17, 2000

CLA-2-44:RR:NC:2:230 G82375


TARIFF NO.: 4421.90.9840

Mr. Louis Reny
Renyco Inc.
175A, rue Alexandre, C.P. 1080
Thurso, Quebec J0X 3B0

RE: The tariff classification of Doweloc™ panel material for the construction of squash court walls from Canada

Dear Mr. Reny:

In your letter dated September 14, 2000 you requested a tariff classification ruling on a product marketed as Doweloc™.

The subject product (Doweloc™ panels) is to be used in the construction of squash court walls. Doweloc™ products feature metal rods which hold and reinforce lumber strips together. Similar Doweloc™ products have been previously ruled on; namely, rail car decking in ruling F88703 dated July 19, 2000 and scaffolding planks in ruling F85424 dated April 17, 2000.

A 6” length sample of the Doweloc™ product presently under consideration was submitted. It consists of 14 strips of maple (each approximately 7/8” thick and 1-5/16” wide) assembled face to face. The faces have a 9/16” wide tongue and groove in the center. The lumber strips are held together by means of aluminum dowel rods which are inserted at intervals across the width of the panel. The wood strips are not glued. The assembled pieces form a 12” wide panel.

In a telephone conversation, you explained that the tongue on the last piece which forms the outer edge of the assembled panel is removed and that the groove remaining on the other outer edge of the panel is diminished. You stated that the tongue is removed and the groove is reduced because they are not precise enough to be used in the assembly of the squash court walls.

The Doweloc™ panels to be imported will be 12” wide, 1-1/2” or 2-1/4” thick and 4’ to 20’ long. The panels will have square ends and essentially square edges. The remaining diminished groove on one edge is not intended to be used for any purpose.

After importation, at the construction site, the panels will be grooved along the edges and ends. The panels will be aligned at the grooves and a wood biscuit will be inserted into the grooves to join the panels together. The 1-1/2” thick panels will be used to make the side walls of squash courts and the 2-1/4” thick panels will be used to make the front walls.

In the condition as imported, the Doweloc™ panels do not have any feature which would make them recognizable as builders’ joinery or carpentry. Although the panels are constructed by the use of metal rods, the panels themselves are general wood material having multiple and similar uses as edge-glued wood.

The applicable subheading for the subject Doweloc™ panel material will be 4421.90.9840, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for other articles of wood; other; other. The general rate of duty will be 3.3 percent ad valorem.

The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in 19 CFR 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect.

This ruling is being issued under the assumption that the subject goods, in their condition as imported into the United States, conform to the facts and the description as set forth both in the ruling request and in this ruling. In the event that the facts or merchandise are modified in any way, you should bring this to the attention of Customs and you should resubmit for a new ruling in accordance with 19 CFR 177.2. You should also be aware that the material facts described in the foregoing ruling may be subject to periodic verification by the Customs Service.

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 212-637-7009.


Robert B. Swierupski

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