The tariff classification of wood fence components from Japan
Active· CBP ruling HQ N347550· Issued 2025-04-15
Ruling text
N347550 April 15, 2025 CLA-2-44:OT:RR:NC:N5:130 CATEGORY: Classification TARIFF NO.: 9903.01.25; 4421.99.7040; 4407.19.0093 Ms. Cathy Yu Cathy C. Yu Co. 13715 Bess St. La Puente, CA 91746 RE: The tariff classification of wood fence components from Japan Dear Ms. Yu: In your letter, dated April 7, 2025, you requested a binding tariff classification ruling on behalf of your client, Sambro Lighthouse International. The ruling was requested on wood fence components. Product information and photos were submitted for our review. The items under consideration are three boards used in the manufacture of fences. Item one is a dog-eared fence picket measuring 140mm wide by 1830mm (6 feet) long by 15mm thick. The top two corners are cut at a 45-degree angle. The second item is a rectangular sawn, planed board measuring 152mm wide by 1830mm long by 15mm thick. The third item is a rectangular sawn, planed board measuring 89mm wide by 2440mm (8 feet) by 38mm thick. All three boards are constructed of Japanese cedar (Cryptomeria japonica, a coniferous wood) wood. The wood does not appear to be finger-jointed to increase the length of the boards. The boards are not treated with paint, stain, creosote, or any other preservative. In your letter, you suggest that the fence components are classifiable under subheading 4404.20.0040, Harmonized Tariff Schedule of the United States, HTSUS. We disagree. Goods of heading 4404, even though the language includes the word “pickets”, do not include all pickets or fence components. The Explanatory Notes to heading 4404 explain that pickets of heading 4404 are “consisting of round or split poles, pointed at the ends, whether or not peeled or impregnated with preservative, but not sawn lengthwise.” “Poles”, as referred to in this language, means whole, round branches. So, the pickets must be either of whole, round branches, pointed at one end, or branches that have been split. The language specifically excludes pickets where the wood is sawn lengthwise, meaning wood that is sawn along the length of the tree, parallel to the grain. The instant wood components are all wood that has been sawn lengthwise, and therefore, classification in heading 4404 is precluded. 6-foot-long, dog-eared pickets are standard pickets within the U.S. fence industry. Therefore, we can classify them as pickets of heading 4421. The other two items are merely wood that have been sawn lengthwise along the grain. There are no specific characteristics of the boards that dedicate them for use in fence manufacturing. Therefore, they will be classified as wood sawn lengthwise, as specifically provided for in heading 4407. The applicable subheading for the 6-foot-long, dog-eared pickets will be 4421.99.7040, HTSUS, which provides for Other articles of wood: Other: Other: Pickets, palings, posts and rails, the foregoing which are sawn; assembled fence sections: Other. The rate of duty will be free. The applicable subheading for the two rectangular sawn boards will be 4407.19.0093, HTSUS, which provides for Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm: Coniferous: Other: Other: Not treated: Other: Other. The rate of duty will be free. Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs.? All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other countries, including Japan, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheadings 4421.99.7040 or 4407.19.0093, HTSUS, listed above. 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 at https://hts.usitc.gov/. 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 laurel.duvall@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division
Source: rulings.cbp.gov — ruling N347550, retrieved 2026-10-12T06:04:44Z, republished verbatim. This digest is informational; only CBP issues binding rulings.