The tariff classification of multilayer wood flooring from Vietnam

N363306
July 21, 2026
CLA-2-44:OT:RR:NC:N5:130
CATEGORY: Classification
TARIFF NO.: 4418.75.7000; 4412.33.3225
Mr. Samuel Focarino Comet Customs Brokers, Inc. 193 East Merrik Rd. Valley Stream, NY 11580 RE: The tariff classification of multilayer wood flooring from Vietnam Dear Mr. Focarino: In your letter, dated July 14, 2026, you requested a binding tariff classification ruling on behalf of your client, Old Master Products, Inc. Product information and samples were submitted for our review. The products under consideration are three styles of engineered - or multilayer - wood flooring. The first measures approximately 190mm wide by 300mm long by 15mm in thickness and has a face ply measuring 4.22mm in thickness. This panel is not surface coated. The second panel measures approximately 240mm wide by 300mm long by 15mm in thickness and has a face ply measuring 3.85mm in thickness. This panel is surface coated with a material that does not obscure the grain of the face ply. The third panel measures approximately 190mm wide by 300mm long by 15mm in thickness and has a face ply measuring 3.89mm in thickness. This panel is surface coated with a material that does not obscure the grain of the face ply. Panels 1 and 2 are constructed of 8 layers or plies and panel 3 is constructed of 9 layers or plies. None of the plies exceeds 6mm in thickness. The grain of each layer generally runs at a 90-degree angle to the grains of the adjacent plies. All three panels consist of an oak (Quercus spp., a nonconiferous wood) face ply, eucalyptus (Eucalyptus spp., a nonconiferous wood) core plies and a back ply of Styrax tonkinensis, a nonconiferous wood. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level (for the 4-digit headings and the 6 digit subheadings) and facilitate classification under the Harmonized Tariff Schedule of the United States (HTSUS) by offering guidance in understanding the scope of the headings and the General Rules of Interpretation (GRIs). While neither legally binding nor dispositive of classification issues, the ENs provide commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of the headings. See T.D. 89-80, 54 Fed. Reg. 35127-28 (Aug. 23, 1989).

The instant multilayer flooring panels meet the definition of “plywood” as set forth in the ENs to heading 4412. “Plywood” is defined as a panel “consisting of three or more sheets of wood glued and pressed one on the other and generally disposed so that the grains of successive layers are at an angle.” The flooring panels are also described by the language “multilayer, assembled flooring panels”. Additional U.S. Note 4(b) to Chapter 44, HTSUS, specifically provides that heading 4418 includes “multi-layer assembled flooring panels having a face ply 4 mm or more in thickness.” Because panel 1 has a face ply measuring 4.22mm in thickness, it is classifiable in heading 4418. Panels 2 and 3, which have face plies measuring less than 4mm in thickness, are classifiable in heading 4412. The applicable subheading for panel 1 will be 4418.75.7000, HTSUS, which provides for Builders' joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and shakes: Assembled flooring panels: Other, multilayer: Other. The general rate of duty will be 5 percent ad valorem. The applicable subheading for panels 2 and 3 will be 4412.33.3225, HTSUS, which provides for Plywood, veneered panels and similar laminated wood: Other plywood consisting solely of sheets of wood (other than bamboo), each ply not exceeding 6mm in thickness: Other, with at least one outer ply of nonconiferous wood of the species alder (Alnus spp.),ash (Fraxinus spp.), beech (Fagus spp.), birch (Betula spp.), cherry (Prunus spp.), chestnut (Castanea spp.), elm (Ulmus spp.), eucalyptus (Eucalyptus spp.), hickory (Carya spp.), horse chestnut (Aesculus spp.), lime (Tilia spp.), maple (Acer spp.), oak (Quercus spp.), plane tree (Platanus spp.), poplar and aspen (Populus spp.), robinia (Robinia spp.), tulipwood (Liriodendron spp.) or walnut (Juglans spp.): Not surface covered, or surface covered with a clear or transparent material which does not obscure the grain, texture or markings of the face ply: Other: Wood flooring. The general rate of duty will be 8 percent ad valorem. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Title 19, Code of Federal Regulations (CFR), Section 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, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Laurel Duvall at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division