The tariff classification of tray fronts from unspecified country or countries.

N285386 May 3, 2017 CLA-2-94:OT:RR:NC:N4:433 CATEGORY: Classification TARIFF NO.: 9403.90.7080 Stephanie Hediger Specified Components Company 1800 Nations Drive, Suite 106 Gurnee, IL 60031 RE: The tariff classification of tray fronts from unspecified country or countries. Dear Ms. Hediger: In your letter dated April 13, 2017, you requested a tariff classification ruling. A schematic diagram and a sample were submitted. The products in question are “solid birch tray fronts” used as front panels of drawer boxes for kitchen cabinets. The tray fronts are cut to size and shape, have wide notched cut-outs for use as handles, and are plow cut running the entire length of the grain along the backside of the panels. The drawer bottoms are inserted into the plow cuts. The tray fronts are sanded on top, surfaced on four sides and end sealed. The tray fronts have Ultraviolet (UV) coatings applied to all surfaces, other than the bottom edges of the panels which are unfinished. The UV top coat consists of two chemical components: epoxy acrylic acid (80%) and monomer (20%). The tray fronts will be imported in measurements of 12.7mm (0.50 of an inch) thick by 3.938 inches wide by 7.969, 9.469, 10.969, 12.969, 13.969, 15.969, 16.969, 18.969, 25.969, 28.812, and 31.969 inches long. These tray fronts are cut to size and shape per customer specifications and are ready to be assembled into drawer boxes. When interpreting and implementing the Harmonized Tariff Schedule of the United States (HTSUS), the Explanatory Notes (ENs) of the Harmonized Commodity Description and Coding System may be utilized. The ENs, while neither legally binding nor dispositive, provide a guiding commentary on the scope of each heading, and are generally indicative of the proper interpretation of the HTSUS. CBP believes the ENs should always be consulted. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The ENs to Chapter 94 of the HTSUS, under the provision for [Parts] state: “This Chapter only covers parts, whether or not in the rough, of the goods of headings 94.01 to 94.03 and 94.05, when identifiable by their shape or other specific feature as parts designed solely or principally for an article of those headings. They are classified in this Chapter when not more specifically covered elsewhere.” As there does not appear to be a heading more specific than heading 9403 (“Other furniture and parts thereof”), it is our opinion that the “solid birch tray fronts” are classifiable in subheading 9403.90, as parts of other furniture. See New York ruling N190260 dated November 15, 2011. The applicable subheading for the “solid birch tray fronts” will be 9403.90.7080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other furniture and parts thereof: Parts: Other: Of wood: Other.” The rate of duty will be free under Column 1, General, HTSUS, provided that the country of origin(s) is one that the United States has “normal trade relations.” 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 https://hts.usitc.gov/current. 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 Neil H. Levy at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division