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April 2024, question 26

Classification · Classification: GRIs, notes and headings

What is the CLASSIFICATION of the following plywood panel? The plywood panel measures 4’ (1.22m) wide x 8’ (2.44m) long x 18mm in thickness, and has 13 wood plies (sheets of wood), each measuring approximately 1.38mm in thickness. The panel has a face ply and back ply (collectively, the “outer plies”) of birch wood (Betula spp., a non- tropical, nonconiferous wood) and the remaining plies are poplar wood (Populus spp., a non-tropical, nonconiferous wood). Both the face and back plies are surface-covered with opaque phenolic resin - a wood sealer - which fully obscures the grain of the wood it covers.

  1. 4412.31.0620
  2. 4412.31.9200
  3. 4412.33.0670
  4. 4412.33.5700
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CBP's answer: D. D: 4412.33.5700

Additional U.S. Note 1(c) to Chapter 44 says a plywood panel is 'surface covered' when its exterior is treated with fillers, sealers, paints and the like. The birch face ply here is covered with opaque phenolic resin that hides the grain, so the lines for 'not surface covered, or covered with clear material' (4412.33.06, 4412.33.32) do not apply. The panel falls in the residual 'Other' line, 4412.33.5700 (D).

with fillers, sealers, waxes, oils, stains, varnishes, paints or enamels Chapter 44, Additional U.S. Note 1
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 4412.33.06

Search for: surface covered

CBP's key cites: HTSUS 4412.33.5700; General Rules of Interpretation; Chapter 44, Note 1

Question and key from CBP's April 2024 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).