The tariff classification of multilayer wood flooring from Indonesia

N363390
July 31, 2026
CLA-2-44:OT:RR:NC:N5:130
CATEGORY: Classification
TARIFF NO.: 4412.31.6100; 4412.31.9200
Mr. Harry Wang PT Layo Sengfong Jl. Prof. Dr. Nurcholish Madjid No. 159 Jombang 61419 Indonesia RE: The tariff classification of multilayer wood flooring from Indonesia Dear Mr. Wang: In your letter, dated July 17, 2026, you requested a binding tariff classification ruling on multilayer wood flooring. Product information and images were submitted for our review. The products under consideration are three styles of engineered – or multilayer – wood flooring. Style 1 is constructed of multiple layers of Mahogany, Gmelina, or Acacia, all tropical woods. The image shows seven layers of wood and you indicate that no layer exceeds 2.5mm in thickness. The grain of each layer runs at a 90-degree angle to the adjacent layers. The panel is overlaid with a layer of melamine-impregnated, printed paper, and the back of the panel is covered with irradiated cross-linked polyethylene (IXPE) foam. Both the paper and the foam obscure the grain of the wood beneath. The panels are tongued and grooved on their edges and ends. Style 2 is constructed of multiple layers of Mahogany, Gmelina, or Acacia, all tropical woods. The image shows eight layers of wood and you indicate that no layer exceeds 2.5mm in thickness. The grain of each layer runs at a 90-degree angle to the adjacent layers. The panel is overlaid with a layer of melamine-impregnated, printed paper. The paper obscures the grain of the wood beneath. The panels are tongued and grooved on their edges and ends. Style 3 is constructed of multiple layers of Mahogany, Gmelina, or Acacia, all tropical woods. The image shows eight layers of wood and you indicate that no layer exceeds 2.5mm in thickness. The grain of each layer runs at a 90-degree angle to the adjacent layers. The panel is overlaid with a layer of high-density fiberboard (HDF) and is covered with a layer of melamine-impregnated, printed paper. The paper and HDF obscure the grain of the wood beneath. The panels are tongued and grooved on their edges and ends.

You suggest that Style 1 is classifiable under subheading 4412.91.5205 or 4418.99.9105, Harmonized Tariff Schedule of the United States (HTSUS). You suggest that Style 2 is classifiable under 4412.31.4875, HTSUS. You suggest that Style 3 is classifiable under 4412.91.5205, HTSUS. We disagree with each of these suggested classifications. Subheading 4412.91.5205, HTSUS, provides for veneered panels that are not plywood; we will show herein that the panels are each of a plywood construction. Subheading 4418.99.9105, HTSUS, provides for single layer wood flooring products that are not classified elsewhere. The instant panels are multilayer. Subheading 4412.31.4875, HTSUS, provides for tropical plywood that is not surface covered or surface covered with a clear or transparent material. All of the panels are surface covered with opaque materials. As such, all of the suggested classifications are precluded. 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.” Plywood is specifically provided for in heading 4412, HTSUS. Note 4 to Chapter 44, HTSUS, sets for that goods of heading 4412 may be tongued and grooved: Products of heading 4410, 4411 or 4412 may be worked to form the shapes provided for in respect of the articles of heading 4409, curved, corrugated, perforated, cut or formed to shapes other than square or rectangular or submitted to any other operation provided it does not give them the character of articles of other headings. Also, the language of subheadings within heading 4412 indicate that the panels may be surface covered. Additional US Note 1(c) to Chapter 44, HTSUS, defines surface covering: The term "surface covered," as applied to the articles of headings 4411 and 4412, means that one or more exterior surfaces of a product have been treated with creosote or other wood preservatives, or with fillers, sealers, waxes, oils, stains, varnishes, paints or enamels, or have been overlaid with paper, fabric, plastics, base metal, or other material. Each of the panels is surface covered with melamine-impregnated, printed paper. Style 3 is also surface covered with HDF. The paper and HDF are both opaque surface coverings that obscure the grain of the wood beneath, therefore, they do not meet the term “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.” Each product is plywood with a surface covering that obscures the grain of the face ply. The applicable subheading for Styles 1, 2, and 3 when there is an outer ply of Mahogany wood will be 4412.31.6100, 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: With at least one outer ply of tropical wood: Other: With at least one outer ply of the following tropical woods: Dark Red Meranti, Light Red Meranti, White Lauan, Sipo, Limba, Okoumé, Obeche, Acajou d'Afrique, Sapelli, Virola, Mahogany, Palissandre de Para, Palissandre de Rio or Palissandre de Rose. The general rate of duty will be 8 percent ad valorem.

The applicable subheading for Styles 1, 2, and 3 when there is a face ply of Gmelina or Acacia will be 4412.31.9200, 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: With at least one outer ply of tropical wood: Other: Other. 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