The tariff classification of die-formed, veneered, HDF door skins

N131659 December 1, 2010 CLA-2-44:OT:RR:NC:2:230 CATEGORY: Classification TARIFF NO.: 4421.90.9760 Mr. Daniel K. Weir Weir Plywood & Door, LLC 219 N. First St. Pacific, MO 63069 RE: The tariff classification of die-formed, veneered, HDF door skins Dear Mr. Weir: On November 6, 2010, you electronically requested a tariff classification ruling. The ruling was requested for die-formed, veneered, high density fiberboard (HDF) door skins. Prior to submitting your electronic request, you submitted photos of the product to this office. You state in your description that the HDF door skins are 2.5mm thick and laminated on one side with hardwood veneer of a thickness of 0.25mm. You add that the panels are unfinished and imported in standard door sizes, with an additional 3/4” in height and 1/2" in width for assembly purposes. You explain that the skins are used by door manufacturers as facings to rail and stile door frames, and that the doors are finished after assembly. The photos provided show that the door skins are molded and veneered to simulate solid wood, raised panel doors, complete with multiple rectangular panels, and tapering, mitering, and beading effects. These shaped skins are then laminated with multiple pieces of veneer, cut and oriented specifically to give the appearance of a rail-and-stile, raised panel door. While this product does appear superficially to be a “veneered panel” of heading 4412, Harmonized Tariff Schedule of the United States (HTSUS), it is more complex in structure and has the dedicated purpose of being part of a door. Headquarters ruling H086296, dated August 24, 2010, explains that “merchandise that has been so processed that it has become a different article cannot be classified in heading 4412, HTSUS.” The door skin, being shaped and veneered to simulate a raised panel door, is not a veneered panel, but is recognizable as a part of a door. As such, it cannot be classified in heading 4412, HTSUS. Although wood doors are classifiable in heading 4418, HTSUS, the instant skin does not constitute a door, but only a part thereof. Classification of door parts is precluded from heading 4418. Therefore, the appropriate heading for the door skins is 4421, HTSUS. The applicable subheading for the die-formed, veneered, HDF door skins will be 4421.90.9760, HTSUS, which provides for: Other articles of wood: Other: Other: Other: Other. The rate of duty will be 3.3 percent, ad valorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Laurel Duvall at (646) 733-3035. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division