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NY N014733

August 24, 2007



TARIFF NO.: 4407.10.0115

Mr. Ross Mollberg
Spruce Top Lumber Sales Ltd.
1797 Dublin Ave., Unit E
Winnipeg, Manitoba R3H 1A9

RE: The tariff classification of block stringer components from Canada

Dear Mr. Mollberg:

In your letter dated July 18, 2007, you resubmitted your request for a tariff classification ruling on block stringer components, along with additional information.

The block stringer components to be classified consist of 3-1/2” x 3-1/2” x 5” blocks and 3-1/2” x ¾” x 35-1/2” boards, composed of spruce/pine/fir (SPF). The components are solid pieces of lumber that have been cut-to-size, planed and graded.

The components will be supplied to a U. S. pallet manufacturer, who will assemble two boards and three blocks together to make a block stringer, measuring 3-1/2” wide x 35-1/2” long x 5” high. The assembled block stringer is the middle component of a block pallet, to be assembled together with top and bottom deckboards to make a block pallet.

You believe that the subject block stringer components should be classified as unassembled stringer boards in subheading 4421.90.9740, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for other articles of wood.

However, in the condition as imported, the components are not processed beyond being cut-to-size planed lumber. The boards are packaged in bundles of 588 pieces per bundle and the blocks are shrink-wrapped on pallets each holding 1440 pieces. The components are not recognizable as anything but lumber material. In this case, the product that you intend to manufacture is a part of a pallet. There are no references in any tariff headings for “stringer boards,” assembled or unassembled. Thus, General Rule of Interpretation 2 (a) is not applicable. (GRI 2(a) states, that “any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, . . . , presented unassembled or disassembled.”)

The applicable subheading for the block stringer components (the SPF blocks and boards), described above, will be 4407.10.0115, HTSUS, which provides for wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm; coniferous; not finger-jointed; not treated; mixtures of spruce, pine and fir (“S-P-F”). The general rate of duty will be free.

Articles classifiable under subheading 4407.10.0115, HTSUS, which are products of Canada are subject to entry requirements based on the U.S./Canadian Softwood Lumber Agreement of 2006 (“SLA-2006”). An interim regulation published in the Federal Register on October 18, 2006, (71 FR 61399), revised section 12.140 of title 19 of the Code of Federal Regulations (19 CFR 12.140), amended Part 163 (19 CFR Part 163), and describes the new entry and recordkeeping requirements.

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 646-733-3035.


Robert B. Swierupski

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