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The Court of International Trade has upheld U.S. Customs and Border Protection’s classification of wooden door stiles and rails as other articles of wood under HTSUS 4421.90.97. These items consist of a 9.5 millimeter-thick pine cap laminated to a base of laminated poplar wood layers, each with a thickness of less than six millimeters. The items have a surface layer of pine wood that is used as the exposed surface. Two of the items have a rebate cut at both ends of the wood, but otherwise the items are constructed the same (though imported in various lengths and thicknesses).
The plaintiff had argued for classification under HTSUS 4412.99.51, stating that the items fit squarely within the common meaning of “veneered panels” or, alternatively, that they constitute “similar laminated wood” because they possess numerous characteristics in common with wood items classified under heading 4412. However, the CIT states that heading 4408 defines sheets for veneering as having a thickness not exceeding 6 mm, a standard that the items at issue exceed. Further, the CIT states that the items do not meet either of the criteria for qualification as “similar laminated wood:” (a) their base layers consist of wood less than 2 mm thick, whereas the Explanatory Notes for heading 4412 specify that the core must be “thick,” and (b) they have a core of wood and not the alternative materials specified, such as wood waste or cork.
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