WEBVTT 00:00:02.000 --> 00:00:03.103 >>: Good afternoon, ladies and 00:00:03.103 --> 00:00:04.917 gentlemen. My name is Lynn Banks from 00:00:04.917 --> 00:00:05.771 the U.S. Customs and border's trade 00:00:05.771 --> 00:00:09.594 relations thank you for joining us today 00:00:09.594 --> 00:00:12.356 for the antidumping countervailing duty 00:00:12.356 --> 00:00:19.946 and section 3014 heading 9403 and 9404, 00:00:19.946 --> 00:00:21.735 furniture, mattresses, pillows, and 00:00:21.735 --> 00:00:24.023 quilted bedding webinar. Today's 00:00:24.023 --> 00:00:28.315 webinar as part of the 2023 education 00:00:28.315 --> 00:00:29.687 commodity specific webinar series and 00:00:29.687 --> 00:00:35.727 has an anticipated duration of an hour. 00:00:35.727 --> 00:00:38.200 We have a few housekeeping items. 00:00:38.200 --> 00:00:40.383 Everyone will be kept on mute during the 00:00:40.383 --> 00:00:42.347 presentation so that we can keep the 00:00:42.347 --> 00:00:44.883 line clear of background noise. If you 00:00:44.883 --> 00:00:47.062 have any questions or comments, we 00:00:47.062 --> 00:00:50.066 invite you to type them into the chat at 00:00:50.066 --> 00:00:51.974 any time during the presentation. We 00:00:51.974 --> 00:00:53.826 will be answering as many questions as 00:00:53.826 --> 00:00:57.212 we can from the chat at the end of the 00:00:57.212 --> 00:00:59.820 presentation and the continuing 00:00:59.820 --> 00:01:02.410 education credit code will be placed in 00:01:02.410 --> 00:01:05.632 the WebExs chat during the presentation. 00:01:05.632 --> 00:01:07.348 Today's presenter is National Import 00:01:07.348 --> 00:01:13.390 Specialist Seth Mazze. Mr. Mazze over 00:01:13.390 --> 00:01:15.975 to you.SETH 00:01:15.975 --> 00:01:17.391 MAZZE: Thank you very much. Hello, 00:01:17.391 --> 00:01:20.679 everyone welcome to our webinar. My 00:01:20.679 --> 00:01:22.430 name is Seth Mazze and my associate Alex 00:01:22.430 --> 00:01:26.975 and I are response before heading 9403, 00:01:26.975 --> 00:01:31.985 and mattresses, pillows, cushions, 00:01:31.985 --> 00:01:33.907 beddings under heading 9404. There's a 00:01:33.907 --> 00:01:35.122 lot of information I will cover so I 00:01:35.122 --> 00:01:37.191 will be moving fast. I apologize up 00:01:37.191 --> 00:01:39.617 front to the closed captioner and two 00:01:39.617 --> 00:01:42.743 others. We are going to start with the 00:01:42.743 --> 00:01:44.413 larger AD/CVD cases and move to the 00:01:44.413 --> 00:01:46.977 smaller cases and then discuss journey 00:01:46.977 --> 00:01:50.400 section 301. Today's webinar will last 00:01:50.400 --> 00:01:52.963 between one hour, maybe one hour and a 00:01:52.963 --> 00:01:55.032 quarter.Please 00:01:55.032 --> 00:01:57.066 jot down questions that you would like 00:01:57.066 --> 00:01:59.820 to ask in case I don't get to them in 00:01:59.820 --> 00:02:02.758 the chat box and I will take them at the 00:02:02.758 --> 00:02:06.191 end or I encourage you to mail them to 00:02:06.191 --> 00:02:07.391 me. I will display the contact 00:02:07.391 --> 00:02:09.581 information that is on the screen at the 00:02:09.581 --> 00:02:11.299 end of the presentation.Let's 00:02:11.299 --> 00:02:23.923 begin with a few introductory slides. 00:02:23.923 --> 00:02:26.828 This is CBP's mission statement and 00:02:26.828 --> 00:02:28.508 within CBP, the Office of Trade mission 00:02:28.508 --> 00:02:30.764 statement. You probably attended other 00:02:30.764 --> 00:02:35.005 webinars so I'm not going to read them. 00:02:35.005 --> 00:02:41.694 This is CBP's disclaimer. Informs you 00:02:41.694 --> 00:02:43.854 that today's webinar is an advisory end 00:02:43.854 --> 00:02:45.972 night binding and the reliance on the 00:02:45.972 --> 00:02:48.512 information in this webinar is not in 00:02:48.512 --> 00:02:50.942 itself reasonable care. Importers are 00:02:50.942 --> 00:02:53.310 encouraged to recognize the binding 00:02:53.310 --> 00:02:55.479 ruling from CBP or the Department of 00:02:55.479 --> 00:02:58.017 Commerce if it is with respect to an 80 00:02:58.017 --> 00:03:01.571 CBD scope or to obtain guidance from a 00:03:01.571 --> 00:03:04.016 private sector expert in customs matter. 00:03:04.016 --> 00:03:07.883 Next is our media the slimmer. Please 00:03:07.883 --> 00:03:09.917 note that all of the images in this 00:03:09.917 --> 00:03:11.586 presentation are the public domain and 00:03:11.586 --> 00:03:14.450 available on the web. They are included 00:03:14.450 --> 00:03:16.156 in this presentation and it does not 00:03:16.156 --> 00:03:18.408 represent an endorsement by CBP. The 00:03:18.408 --> 00:03:21.062 visual media is provided for educational 00:03:21.062 --> 00:03:22.806 purposes only. I also want to note that 00:03:22.806 --> 00:03:27.519 many of the custom rulings online search 00:03:27.519 --> 00:03:28.936 system that I've written including ages 00:03:28.936 --> 00:03:31.612 of the subject articles, the images will 00:03:31.612 --> 00:03:34.578 not display in your web browser, but 00:03:34.578 --> 00:03:36.221 only when the work file is downloaded. 00:03:36.221 --> 00:03:37.932 In almost all businesses you will note 00:03:37.932 --> 00:03:39.952 that there are embedded images because 00:03:39.952 --> 00:03:42.298 they were "image" will be displayed in 00:03:42.298 --> 00:03:44.164 the text next to the document.I 00:03:44.164 --> 00:03:46.174 take this moment to thank those of you 00:03:46.174 --> 00:03:48.393 who've allowed me to include images of 00:03:48.393 --> 00:03:50.424 your products and my rulings. This is 00:03:50.424 --> 00:03:52.872 useful to me and the trade when 00:03:52.872 --> 00:03:56.834 researching matters.Here 00:03:56.834 --> 00:04:00.991 is the link for recording that this and 00:04:00.991 --> 00:04:08.685 other CBP webinars have. This 00:04:08.685 --> 00:04:10.834 presentation will be posted for the 00:04:10.834 --> 00:04:12.982 Trade community at the URL shown on the 00:04:12.982 --> 00:04:15.347 screen. You can screenshot it or take a 00:04:15.347 --> 00:04:18.211 picture. This URL will be repeated at 00:04:18.211 --> 00:04:20.182 the end of the presentation. Next I 00:04:20.182 --> 00:04:22.001 begin our presentation on the side with 00:04:22.001 --> 00:04:24.727 the list of the 80 CBD cases we are 00:04:24.727 --> 00:04:28.537 going to cover. These are the 80 CBD 00:04:28.537 --> 00:04:31.465 cases and headings 9403 and 9404. We 00:04:31.465 --> 00:04:33.206 are going to pay more attention to the 00:04:33.206 --> 00:04:36.676 larger and more complex ones. As you 00:04:36.676 --> 00:04:38.580 can see most cases are for Chinese 00:04:38.580 --> 00:04:40.244 merchandise with only mattresses, 00:04:40.244 --> 00:04:43.773 mattress inner springs, and boat bliss 00:04:43.773 --> 00:04:44.943 shelving having cases from other 00:04:44.943 --> 00:04:48.186 countries, but I know the antidumping 00:04:48.186 --> 00:04:50.489 case from Malaysia and VMEs, wooden 00:04:50.489 --> 00:04:53.952 cabinets is in progress. Of course CBP 00:04:53.952 --> 00:04:58.308 does not make 80 or CBD scope 00:04:58.308 --> 00:04:59.383 determinations. The Department of 00:04:59.383 --> 00:05:00.977 Commerce does. If you want to know for 00:05:00.977 --> 00:05:02.926 sure you need to get a scope ruling from 00:05:02.926 --> 00:05:07.438 them. We will start with mattresses. 00:05:07.438 --> 00:05:09.278 We are starting on the mattress case 00:05:09.278 --> 00:05:12.575 because it is more than half of this 00:05:12.575 --> 00:05:13.906 branch, the consumer products and 00:05:13.906 --> 00:05:18.951 disclaimer materials branches AD CBD and 00:05:18.951 --> 00:05:20.766 it is particularly confounding. As 00:05:20.766 --> 00:05:22.968 consumers we are all familiar with 00:05:22.968 --> 00:05:26.533 mattresses. As you can see there are AD 00:05:26.533 --> 00:05:29.668 CBD cases on mattresses from these eight 00:05:29.668 --> 00:05:31.901 countries. In the interest of 00:05:31.901 --> 00:05:33.782 compliance, and that is what we all 00:05:33.782 --> 00:05:36.730 want, compliance, I want to help you 00:05:36.730 --> 00:05:39.537 understand this scope.The 00:05:39.537 --> 00:05:40.591 Chinese antidumping scope is a little 00:05:40.591 --> 00:05:44.609 bit different from the Chinese 00:05:44.609 --> 00:05:47.077 anti-countervailing duty scope and other 00:05:47.077 --> 00:05:48.602 country's scope.In 00:05:48.602 --> 00:05:49.414 case you're interested I have asked to 00:05:49.414 --> 00:05:52.965 distribute a comparison table for all of 00:05:52.965 --> 00:05:55.295 attendees. I don't know if that will 00:05:55.295 --> 00:05:56.189 functions with you don't receive that in 00:05:56.189 --> 00:05:57.912 the next few days and you are 00:05:57.912 --> 00:06:00.322 interested, you can certainly email 00:06:00.322 --> 00:06:01.196 me.So 00:06:01.196 --> 00:06:09.743 what is in the mattress scope? All 00:06:09.743 --> 00:06:12.299 mattresses in scope are on mattresses 00:06:12.299 --> 00:06:17.154 larger than 39 inches by 25 inches by 00:06:17.154 --> 00:06:18.867 two introduces. Irrespective of 00:06:18.867 --> 00:06:20.583 construction, irrespective of the number 00:06:20.583 --> 00:06:24.563 of the type of bolts, irrespective of 00:06:24.563 --> 00:06:26.976 whether it is imported alone, with the 00:06:26.976 --> 00:06:30.060 foundation, as part of a chest to bed, 00:06:30.060 --> 00:06:32.506 sofa bed, or Murphy bed. What is out of 00:06:32.506 --> 00:06:41.427 scope? So what is not in scope? 00:06:41.427 --> 00:06:44.988 Bassinet pads smaller than 39 by 25 by 00:06:44.988 --> 00:06:48.803 two are not in scope. Gurney or 00:06:48.803 --> 00:06:51.373 stretcher mattresses and pads are not in 00:06:51.373 --> 00:06:54.423 scope. Play yard pads and mattresses 00:06:54.423 --> 00:07:06.383 are not in scope.Camp 00:07:06.383 --> 00:07:10.040 mats and pads, whether pneumatic, foam, 00:07:10.040 --> 00:07:11.377 or self-inflating, or otherwise or out 00:07:11.377 --> 00:07:16.416 of scope. Yoga mats are out of scope 00:07:16.416 --> 00:07:17.740 and air beds and air mattresses and 00:07:17.740 --> 00:07:26.007 waterbeds are out of scope. Even the 00:07:26.007 --> 00:07:27.226 soft sided waterbed that looks like a 00:07:27.226 --> 00:07:27.910 regular mattress like this one are out 00:07:27.910 --> 00:07:39.772 of scope. What else is out of scope? 00:07:39.772 --> 00:07:42.969 Peg beds or mattresses are out of scope, 00:07:42.969 --> 00:07:46.572 mattress toppers of 4 inches or less. 00:07:46.572 --> 00:07:48.596 It doesn't matter if they are uncovered, 00:07:48.596 --> 00:07:50.471 contoured foam like the image on the 00:07:50.471 --> 00:07:52.012 left, or a covered sheet of foam like 00:07:52.012 --> 00:07:55.096 the one on the right. What else is out 00:07:55.096 --> 00:08:01.587 of scope? Tufted futon mattresses are 00:08:01.587 --> 00:08:05.675 out of scope. Frameless futon seat 00:08:05.675 --> 00:08:08.976 chairs are out of scope. And I have 00:08:08.976 --> 00:08:09.904 just one more out of scope 00:08:09.904 --> 00:08:19.355 slide.Multifunction 00:08:19.355 --> 00:08:21.247 furniture that converts from seating to 00:08:21.247 --> 00:08:24.949 sleeping, that is a sofa bed with the 00:08:24.949 --> 00:08:27.243 mattress integrated into and inseparable 00:08:27.243 --> 00:08:29.309 from the furniture frame is out of 00:08:29.309 --> 00:08:39.911 scope. This last image, the sofa bed is 00:08:39.911 --> 00:08:43.373 where I think we see the most amazing 00:08:43.373 --> 00:08:46.697 risk. If this is a Chinese mattress, 00:08:46.697 --> 00:08:49.379 even if the sofa bed were made in let's 00:08:49.379 --> 00:08:51.201 say India which doesn't have an 00:08:51.201 --> 00:08:52.911 antidumping case on mattresses, the 00:08:52.911 --> 00:08:54.393 Chinese mattress would still be subject 00:08:54.393 --> 00:09:00.297 to the Chinese AD CBD cases. How do I 00:09:00.297 --> 00:09:04.632 know this? We have a ruling in cross 00:09:04.632 --> 00:09:07.153 for a Taiwanese mattress that is 00:09:07.153 --> 00:09:09.394 incorporated into a Chinese sofa bed in 00:09:09.394 --> 00:09:10.945 China it was the time Taiwanese origin 00:09:10.945 --> 00:09:12.287 of the mattress is maintained. I will 00:09:12.287 --> 00:09:14.570 give you the ruling number in just a 00:09:14.570 --> 00:09:17.299 minute. I point this out because we are 00:09:17.299 --> 00:09:19.453 all looking for compliance. But he 00:09:19.453 --> 00:09:25.195 wants a "gotcha." Be aware that we at 00:09:25.195 --> 00:09:26.847 CBP are on the lookout for supplements 00:09:26.847 --> 00:09:31.684 because of we are aware of the AD CBD 00:09:31.684 --> 00:09:33.924 trade evasion. You want to find this 00:09:33.924 --> 00:09:36.813 out before we do.Let's 00:09:36.813 --> 00:09:41.344 talk briefly about folding mattresses. 00:09:41.344 --> 00:09:45.561 Don't confuse this portable trifold 00:09:45.561 --> 00:09:47.619 mattress that is in scope with the 00:09:47.619 --> 00:09:50.295 previous picture of an out of scope 00:09:50.295 --> 00:10:01.007 frameless futon chair. This second 00:10:01.007 --> 00:10:02.197 picture in an example of an in scope 00:10:02.197 --> 00:10:08.393 C-fold mattress in a chest bed — next a 00:10:08.393 --> 00:10:17.334 fun fact. The Chinese all other 00:10:17.334 --> 00:10:22.930 antidumping rate is 1730 1.75%. 00:10:22.930 --> 00:10:28.524 Yikes!Most 00:10:28.524 --> 00:10:34.570 Chinese specific rates are only 162.76%. 00:10:34.570 --> 00:10:37.640 By far the greatest value of mattresses 00:10:37.640 --> 00:10:39.116 subject to antidumping are from 00:10:39.116 --> 00:10:43.960 Indonesia, likely because they're all 00:10:43.960 --> 00:10:51.990 other deposit rate is only 2.22%Let's 00:10:51.990 --> 00:10:55.535 look at mattress deposit rates. This 00:10:55.535 --> 00:10:57.254 slide summarizes our current deposit 00:10:57.254 --> 00:10:59.597 rates on mattresses. You see that the 00:10:59.597 --> 00:11:03.627 Indonesia rate like I said is only 00:11:03.627 --> 00:11:06.959 2.22%. But know that the Vietnamese all 00:11:06.959 --> 00:11:11.818 other rate is also a whopping 668%. I 00:11:11.818 --> 00:11:15.129 will give you a moment to take a look at 00:11:15.129 --> 00:11:18.831 some of the other case numbers and the 00:11:18.831 --> 00:11:21.183 all other and specific rates of 00:11:21.183 --> 00:11:34.023 duty.Mattress 00:11:34.023 --> 00:11:37.221 classification is a little tricky. 00:11:37.221 --> 00:11:40.588 First, mattress supports, also known as 00:11:40.588 --> 00:11:48.202 box springs go here. Second, mattresses 00:11:48.202 --> 00:11:52.942 with foam cores are classified in 00:11:52.942 --> 00:11:56.961 9404.20 1.00 as our hybrid mattresses, 00:11:56.961 --> 00:12:01.431 those with both foam and spring 00:12:01.431 --> 00:12:07.628 quarters. This is per New York ruling N 00:12:07.628 --> 00:12:09.407 276753. I will share that ruling in a 00:12:09.407 --> 00:12:14.687 few moments.A 00:12:14.687 --> 00:12:16.919 mattress with a cotton core, if you are 00:12:16.919 --> 00:12:24.239 ever to see one would be classified in 00:12:24.239 --> 00:12:26.598 9404.29.10.So 00:12:26.598 --> 00:12:29.755 where are typical mattresses with spring 00:12:29.755 --> 00:12:30.972 course classified? Mattresses with 00:12:30.972 --> 00:12:37.442 spring cores are classified here in 00:12:37.442 --> 00:12:40.919 9404.29.90 and if they are twins or 00:12:40.919 --> 00:12:42.588 larger, then they are in suffix AD 00:12:42.588 --> 00:12:45.579 seven. However, if the importation is 00:12:45.579 --> 00:12:47.014 for naked coils, that is just the 00:12:47.014 --> 00:12:51.394 springs with a border wire, then they go 00:12:51.394 --> 00:12:54.934 in statistical stuff YX zero five, 13, 00:12:54.934 --> 00:12:59.017 or 50. And uncover, as an uncovered 00:12:59.017 --> 00:13:02.239 innerspring units, if you wonder when an 00:13:02.239 --> 00:13:03.801 uncovered innerspring unit is, think of 00:13:03.801 --> 00:13:07.997 a spring with a wire or rod holding them 00:13:07.997 --> 00:13:12.321 together without foam, quilting, taking. 00:13:12.321 --> 00:13:12.913 Mattress inner springs that are not 00:13:12.913 --> 00:13:14.452 connected in the shape of a mattress are 00:13:14.452 --> 00:13:23.022 classified in (732)620-0090 as articles 00:13:23.022 --> 00:13:26.948 of iron or steel wire or other.The 00:13:26.948 --> 00:13:29.143 number to superscript on this in the 00:13:29.143 --> 00:13:32.828 preceding side tells us that section 301 00:13:32.828 --> 00:13:34.532 of duties apply to Chinese origin 00:13:34.532 --> 00:13:38.624 mattresses and inner springs. Next some 00:13:38.624 --> 00:13:42.209 mattress rulings of note. This first 00:13:42.209 --> 00:13:50.150 ruling N276753 is the one I mentioned. 00:13:50.150 --> 00:13:53.766 It is hybrid mattresses are classified in 00:13:53.766 --> 00:14:00.493 9404.2 1.0013 as mattresses of cellular 00:14:00.493 --> 00:14:02.050 rubber or plastic because the phone 00:14:02.050 --> 00:14:04.342 provides the essential character.That 00:14:04.342 --> 00:14:05.959 should make people happy because it has 00:14:05.959 --> 00:14:08.770 a lower duty rate of 3% is that of the 00:14:08.770 --> 00:14:13.001 alternative which is 6%. Another ruling 00:14:13.001 --> 00:14:21.768 of interest is N3197654, a roll up 00:14:21.768 --> 00:14:24.421 lounger. This is a reminder if it walks 00:14:24.421 --> 00:14:27.057 like a mattress and talks like a 00:14:27.057 --> 00:14:29.214 mattress, then it is a mattress, even if 00:14:29.214 --> 00:14:34.977 it is called something else.In 00:14:34.977 --> 00:14:37.757 N315271, a Taiwanese mattress is 00:14:37.757 --> 00:14:40.962 incorporated into a Chinese sofa bed in 00:14:40.962 --> 00:14:42.835 China. The Taiwanese mattress maintains 00:14:42.835 --> 00:14:45.577 its origin. In this case, since it was 00:14:45.577 --> 00:14:48.380 a Taiwanese mattress, there was no AD 00:14:48.380 --> 00:14:51.391 CVD. However, if we were to reverse the 00:14:51.391 --> 00:14:53.883 origins and operations, the mattress 00:14:53.883 --> 00:14:56.538 would be subject to Chinese AD CVD with 00:14:56.538 --> 00:14:59.010 potentially catastrophic results for the 00:14:59.010 --> 00:15:07.483 importer. And finally in N312932, and 00:15:07.483 --> 00:15:09.582 expensive Indonesian chest bed with an 00:15:09.582 --> 00:15:11.427 inexpensive Chinese mattress inserted 00:15:11.427 --> 00:15:18.818 into it in Indonesia, CBP said the 00:15:18.818 --> 00:15:22.497 origin of the unit is Indonesia. I 00:15:22.497 --> 00:15:26.234 would however apply this ruling very 00:15:26.234 --> 00:15:28.995 narrowly and very carefully.Frankly, 00:15:28.995 --> 00:15:41.688 I would not apply this ruling. So now 00:15:41.688 --> 00:15:43.912 we have gone from the mattress 00:15:43.912 --> 00:15:45.478 antidumping case to an entirely 00:15:45.478 --> 00:15:48.865 different antidumping case. This is 00:15:48.865 --> 00:15:53.809 mattress innerspring antidumping case 00:15:53.809 --> 00:15:56.246 although it was brought by the same 00:15:56.246 --> 00:16:04.802 petitioner, Platinum Legget. There are 00:16:04.802 --> 00:16:07.936 countries from China, South Africa, 00:16:07.936 --> 00:16:13.573 Vietnam, Macao, and deposit rates range 00:16:13.573 --> 00:16:17.762 from 116 to 234%. And all styles of 00:16:17.762 --> 00:16:20.350 inner frames are in scope. And there 00:16:20.350 --> 00:16:23.822 are no corresponding CVD cases.Next 00:16:23.822 --> 00:16:28.613 is an image of some inner springs.So 00:16:28.613 --> 00:16:30.746 all styles of inner springs are within 00:16:30.746 --> 00:16:34.015 scope. The first picture on the left is 00:16:34.015 --> 00:16:36.040 the older less expensive Bonnell Coils 00:16:36.040 --> 00:16:38.372 innerspring. If it has a wire rim like 00:16:38.372 --> 00:16:44.206 this one, than it is classified in 00:16:44.206 --> 00:16:47.778 9404.29.90 and the statistical Suffolk 00:16:47.778 --> 00:16:49.298 is most likely 13, but depends on the 00:16:49.298 --> 00:16:53.933 size. The Pocket Coils on the right are 00:16:53.933 --> 00:16:57.002 better style and have isolation. If 00:16:57.002 --> 00:16:58.199 they are glued like a mattress as you 00:16:58.199 --> 00:17:00.379 see on the top right or covered in 00:17:00.379 --> 00:17:03.060 fabric in the form of a mattress on the 00:17:03.060 --> 00:17:04.202 bottom right, then they are classified 00:17:04.202 --> 00:17:10.967 in 9404.29.90 as uncovered innerspring's 00:17:10.967 --> 00:17:12.853 and again the statistical suffix is most 00:17:12.853 --> 00:17:16.655 likely 13, but it depends on the size. 00:17:16.655 --> 00:17:17.908 As I mentioned if the coils are not 00:17:17.908 --> 00:17:20.655 presented in the form of a mattress like 00:17:20.655 --> 00:17:23.481 in the bottom left picture, then they 00:17:23.481 --> 00:17:25.623 have the essential character of a 00:17:25.623 --> 00:17:28.065 mattress and are classified as other 00:17:28.065 --> 00:17:34.736 articles of wire or steel wire in 00:17:34.736 --> 00:17:36.269 7326.20.0090. This is what this looks 00:17:36.269 --> 00:17:47.738 like.HTSUS 00:17:47.738 --> 00:17:49.144 9404.29.90.13 is uncovered wire and 00:17:49.144 --> 00:17:51.239 pocket because connected together for a 00:17:51.239 --> 00:17:53.906 case so as to meet the specified 00:17:53.906 --> 00:17:55.492 measurements. The number 2 superscript 00:17:55.492 --> 00:17:59.373 tells us that section 301 duties apply 00:17:59.373 --> 00:18:02.132 if they are a Chinese origin.I 00:18:02.132 --> 00:18:04.003 will give you a couple of useful 00:18:04.003 --> 00:18:10.717 innerspring rulings. This first 00:18:10.717 --> 00:18:20.004 ruling, the ruling number N320075 is 00:18:20.004 --> 00:18:21.427 crossed out and I've taken the liberty 00:18:21.427 --> 00:18:23.925 to do that because there is a pending 00:18:23.925 --> 00:18:29.685 ruling, H32H725 that I believe will 00:18:29.685 --> 00:18:34.135 likely revoke the New York ruling and 00:18:34.135 --> 00:18:36.525 reclassified the pocket coil mattress 00:18:36.525 --> 00:18:44.145 core in 9404.29.9013. The second ruling 00:18:44.145 --> 00:18:50.974 that I have here N241845 is inner 00:18:50.974 --> 00:18:54.344 springs with a border wire/ride and it 00:18:54.344 --> 00:18:58.180 classifies them in 9404.29.90 and 00:18:58.180 --> 00:19:03.496 different differentiates inner springs 00:19:03.496 --> 00:19:09.531 without border wire/rod in 7326.20.0071. 00:19:09.531 --> 00:19:12.693 That includes mattress inner springs. 00:19:12.693 --> 00:19:14.734 Now we move on to Chinese wooden cabinets 00:19:14.734 --> 00:19:17.947 and vanities which is another very large 00:19:17.947 --> 00:19:22.772 AD CVD case. As consumers, we are all 00:19:22.772 --> 00:19:25.237 familiar with within cabinets and 00:19:25.237 --> 00:19:27.146 vanities. The case is currently of 00:19:27.146 --> 00:19:28.924 those with only Chinese origin although 00:19:28.924 --> 00:19:31.126 an industry petition to have it expanded 00:19:31.126 --> 00:19:33.680 to include Malaysia and Vietnam is 00:19:33.680 --> 00:19:36.539 currently under review. So what is in 00:19:36.539 --> 00:19:43.890 the scope? In scope wooden cabinets and 00:19:43.890 --> 00:19:46.172 vanities for permanent installation and 00:19:46.172 --> 00:19:48.140 wooden components thereof, floor 00:19:48.140 --> 00:19:52.375 mounted, wall-mounted, ceiling hung, or 00:19:52.375 --> 00:19:54.794 by attachment of plumbing. They are 00:19:54.794 --> 00:19:57.605 substantially upward, engineered wood 00:19:57.605 --> 00:20:00.524 which includes all kinds of things, 00:20:00.524 --> 00:20:03.405 plywood, strand board, Blackboard, 00:20:03.405 --> 00:20:07.209 particleboard, fiberboard, MDF, etc. 00:20:07.209 --> 00:20:08.331 They are irrespective of whether 00:20:08.331 --> 00:20:11.959 imported with faucets, plumbing, sinks, 00:20:11.959 --> 00:20:13.732 countertops, etc. Irrespective of 00:20:13.732 --> 00:20:16.314 whether covered in a wood veneer, wood 00:20:16.314 --> 00:20:19.589 paper, or other overlays or laminate's 00:20:19.589 --> 00:20:21.347 and irrespective of whether it is 00:20:21.347 --> 00:20:27.601 finished or complete.The 00:20:27.601 --> 00:20:30.257 scope very broadly includes cabinets and 00:20:30.257 --> 00:20:34.568 vanity parts. So the cabinet bogs and 00:20:34.568 --> 00:20:36.844 wooden parts irrespective of non-wood 00:20:36.844 --> 00:20:39.122 components or trim of metal, marble, 00:20:39.122 --> 00:20:41.758 glass, plastic, etc. And it includes 00:20:41.758 --> 00:20:44.520 the wooden frames, it includes wooden 00:20:44.520 --> 00:20:48.829 cabinets and vanity boxes, which briefly 00:20:48.829 --> 00:20:51.450 include all of those listed parts. It 00:20:51.450 --> 00:20:53.688 includes wooden cabinet or vanity doors. 00:20:53.688 --> 00:20:56.180 It includes wooden cabinet or vanity 00:20:56.180 --> 00:20:58.829 doors and drawer components, which 00:20:58.829 --> 00:21:01.145 typically include all of the indicated 00:21:01.145 --> 00:21:03.998 parts. It includes wooden back panels 00:21:03.998 --> 00:21:07.769 and end panels. If there are attached 00:21:07.769 --> 00:21:10.373 desks, shelves, and tables, and it 00:21:10.373 --> 00:21:11.792 doesn't matter if they're ready to 00:21:11.792 --> 00:21:18.037 assemble articles, flat packs.As 00:21:18.037 --> 00:21:21.008 you can see the wooden cabinets and 00:21:21.008 --> 00:21:25.974 vanity scope is very broad, both the 00:21:25.974 --> 00:21:30.276 article and the components. So what is 00:21:30.276 --> 00:21:37.599 out of scope? So before there, let me 00:21:37.599 --> 00:21:42.580 go there. So the scope is very broad 00:21:42.580 --> 00:21:44.953 and includes cabinets and vanity parts. 00:21:44.953 --> 00:21:46.176 In scope components that are been 00:21:46.176 --> 00:21:48.776 further processed in another country 00:21:48.776 --> 00:21:49.952 remain in scope even if they have been 00:21:49.952 --> 00:21:52.550 subject to one or more of the following 00:21:52.550 --> 00:21:58.154 operations. Or any other processing 00:21:58.154 --> 00:22:00.421 that would not have removed the 00:22:00.421 --> 00:22:03.239 merchandise from the scope, if it had 00:22:03.239 --> 00:22:05.264 been performed in the in-scope 00:22:05.264 --> 00:22:11.952 country.Let 00:22:11.952 --> 00:22:14.605 me reiterate, once a Chinese cabinet 00:22:14.605 --> 00:22:18.536 part is subject to antidumping, it will 00:22:18.536 --> 00:22:22.509 almost certainly remain subject to 00:22:22.509 --> 00:22:22.509 antidumping no matter what further 00:22:22.509 --> 00:22:24.577 processing is performed on it anywhere 00:22:24.577 --> 00:22:26.579 or even if, or particularly, if it were 00:22:26.579 --> 00:22:28.833 to become a cabinet somewhere else. Let 00:22:28.833 --> 00:22:32.135 me be very clear: Manufacturers in 00:22:32.135 --> 00:22:34.812 Vietnam, Malaysia, Thailand, Canada, 00:22:34.812 --> 00:22:36.745 Mexico or anywhere else cannot use 00:22:36.745 --> 00:22:37.965 Chinese cabinet parts to manufacture 00:22:37.965 --> 00:22:42.162 cabinets for export to the US without 00:22:42.162 --> 00:22:43.588 paying Chinese antidumping and 00:22:43.588 --> 00:22:45.843 countervailing duties.Next 00:22:45.843 --> 00:22:51.294 what is out of scope? Drawer dividers 00:22:51.294 --> 00:22:54.239 such as those shown in the first two 00:22:54.239 --> 00:22:55.890 images and built-in Lazy Susan's like 00:22:55.890 --> 00:22:58.721 those in the last two images are out of 00:22:58.721 --> 00:23:01.093 scope if imported separately. So 00:23:01.093 --> 00:23:05.681 aftermarket. There are also some parts 00:23:05.681 --> 00:23:13.016 that are out of scope. They are 00:23:13.016 --> 00:23:14.234 primarily decorative accessory including 00:23:14.234 --> 00:23:18.159 corbels and rosettes. They are out of 00:23:18.159 --> 00:23:24.192 scope. The first image is a corbel and 00:23:24.192 --> 00:23:29.212 the second image is a rosette. Also 00:23:29.212 --> 00:23:30.314 secondly, imported non-wood hardware is 00:23:30.314 --> 00:23:35.128 out of scope. Non-wood and hardware is 00:23:35.128 --> 00:23:37.525 out of scope and imported separately 00:23:37.525 --> 00:23:40.226 however if hardware is imported with the 00:23:40.226 --> 00:23:42.088 cabinet, whether or not attached, that 00:23:42.088 --> 00:23:45.150 it is just part of the cabinet and it is 00:23:45.150 --> 00:23:49.724 in scope.Antidumping 00:23:49.724 --> 00:23:51.536 and countervailing duty cases are 00:23:51.536 --> 00:23:56.344 expressly excluded from this one are 00:23:56.344 --> 00:23:59.357 wooden bedroom furniture components from 00:23:59.357 --> 00:24:05.019 China A570-890 and hardwood plywood from 00:24:05.019 --> 00:24:16.718 China A570-051 AND C570-052. What about 00:24:16.718 --> 00:24:20.595 an article subject to multiple AD CVD 00:24:20.595 --> 00:24:23.124 cases?What 00:24:23.124 --> 00:24:27.400 AD CVD case should be used on 7501 to 00:24:27.400 --> 00:24:29.201 make entry on the Chinese kitchen 00:24:29.201 --> 00:24:38.259 cabinet with a quartz service product 00:24:38.259 --> 00:24:39.331 QSP counter and a drawn stainless till 00:24:39.331 --> 00:24:41.733 sync? All of these are Chinese. The 00:24:41.733 --> 00:24:47.358 wooden cabinet as this antidumping and 00:24:47.358 --> 00:24:50.051 countervailing duty number, the courts 00:24:50.051 --> 00:24:52.247 service product, these are the man-made 00:24:52.247 --> 00:25:02.397 stone surfaces as this antidumping and 00:25:02.397 --> 00:25:04.390 countervailing duty number, a drawn 00:25:04.390 --> 00:25:10.048 stainless steel sink has this 00:25:10.048 --> 00:25:10.514 antidumping duty number. Indicate in 00:25:10.514 --> 00:25:12.829 the chat box what you think. I will 00:25:12.829 --> 00:25:22.214 give you a minute.I 00:25:22.214 --> 00:25:24.328 really hope no one is importing one of 00:25:24.328 --> 00:25:38.604 these. All right, we have a really big 00:25:38.604 --> 00:25:46.084 selection. And a lot of people are 00:25:46.084 --> 00:25:54.965 saying A and D, and frankly, the case 00:25:54.965 --> 00:25:58.186 resulting in the highest total deposit 00:25:58.186 --> 00:26:00.592 which is likely the Chinese wooden 00:26:00.592 --> 00:26:08.383 cabinet case, so it probably is A and D 00:26:08.383 --> 00:26:10.983 since A would be a percentage of the 00:26:10.983 --> 00:26:13.942 total value of the article and not just 00:26:13.942 --> 00:26:15.719 a percentage of the less expensive QSP 00:26:15.719 --> 00:26:20.462 countertop or a percentage of the drawn 00:26:20.462 --> 00:26:22.475 stainless steel sink. In all 00:26:22.475 --> 00:26:28.265 likelihood, the highest total deposit 00:26:28.265 --> 00:26:30.096 case would be A, the wooden cabinet 00:26:30.096 --> 00:26:40.527 case.Classification 00:26:40.527 --> 00:26:42.555 of wooden cabinets and vanities are 00:26:42.555 --> 00:26:49.492 easy. They are either 9403.40.90.60, 00:26:49.492 --> 00:26:51.390 wooden furniture for further 00:26:51.390 --> 00:26:57.074 installation, or 9403.60.81, wooden 00:26:57.074 --> 00:26:58.622 furniture other than that used in the 00:26:58.622 --> 00:27:04.431 kitchen or bedroom.The 00:27:04.431 --> 00:27:07.229 superscript two of course tells us that 00:27:07.229 --> 00:27:10.620 if they are Chinese origin, section 301 00:27:10.620 --> 00:27:14.211 duties of 25% apply. As for wooden 00:27:14.211 --> 00:27:18.216 cabinet and vanity parts, they are 00:27:18.216 --> 00:27:23.776 classified as wooden furniture parts in 00:27:23.776 --> 00:27:25.425 9403.91.00.80. We again see the number 00:27:25.425 --> 00:27:29.645 2 subscript, superscript for Chinese 00:27:29.645 --> 00:27:32.840 section 301 duties. Back includes 00:27:32.840 --> 00:27:34.775 wooden cabinets and vanities.Now 00:27:34.775 --> 00:27:37.090 we look at the third large value 00:27:37.090 --> 00:27:39.350 antidumping case, Chinese wooden bedroom 00:27:39.350 --> 00:27:44.394 furniture. As consumers, we are all 00:27:44.394 --> 00:27:46.426 familiar with wooden bedroom furniture. 00:27:46.426 --> 00:27:51.964 All of the deposit rate is 216%; 00:27:51.964 --> 00:27:52.631 however, there are many, many 00:27:52.631 --> 00:27:55.349 manufacturers with specific rates of 00:27:55.349 --> 00:27:59.776 zero and others with rates of 6.68% and 00:27:59.776 --> 00:28:01.675 of course some are higher. Next we will 00:28:01.675 --> 00:28:07.678 discuss the scope. The scope says that 00:28:07.678 --> 00:28:11.139 would includes engineered woods, think 00:28:11.139 --> 00:28:16.166 plywood, chipboard, MDF, etc. And it 00:28:16.166 --> 00:28:18.950 may be with or without veneers, llamas, 00:28:18.950 --> 00:28:23.527 or non-wood components or trim. It is a 00:28:23.527 --> 00:28:25.946 simple, unassembled, complete, 00:28:25.946 --> 00:28:28.151 incomplete, finished, or unfinished 00:28:28.151 --> 00:28:32.296 bedroom furniture. The in scope list of 00:28:32.296 --> 00:28:33.895 items is very long providing many, many 00:28:33.895 --> 00:28:38.288 examples.I 00:28:38.288 --> 00:28:40.908 am going to give you a minute to read 00:28:40.908 --> 00:28:44.370 this list on your own. Go ahead and 00:28:44.370 --> 00:29:30.881 start please. Just a little bit more 00:29:30.881 --> 00:29:50.810 time. Okay. On my next slide I have 00:29:50.810 --> 00:29:52.540 the in scope highlights. Hopefully, you 00:29:52.540 --> 00:30:00.025 were able to finish this. This is the 00:30:00.025 --> 00:30:02.773 greatest hit slide with some of the most 00:30:02.773 --> 00:30:04.301 common in scope pieces of bedroom 00:30:04.301 --> 00:30:07.002 furniture. It includes wooden beds, 00:30:07.002 --> 00:30:09.184 wooden headboards, but boards, side 00:30:09.184 --> 00:30:12.396 rails, and canopies, night tables, 00:30:12.396 --> 00:30:16.056 nightstands, bedside tables, dressers, 00:30:16.056 --> 00:30:19.150 bureaus, chest of drawers, dressers with 00:30:19.150 --> 00:30:21.276 and without attached mirrors. And in 00:30:21.276 --> 00:30:22.993 all likelihood if you think of it as 00:30:22.993 --> 00:30:25.288 wooden bedroom furniture, then most 00:30:25.288 --> 00:30:27.228 likely it is wooden bedroom furniture 00:30:27.228 --> 00:30:30.227 and within the scope. That is unless 00:30:30.227 --> 00:30:34.309 you find a specific exclusion.Now 00:30:34.309 --> 00:30:36.727 the out of scope list is at least as 00:30:36.727 --> 00:30:39.330 long as the in scope list. I am going 00:30:39.330 --> 00:30:42.575 to give you another short minute to read 00:30:42.575 --> 00:30:43.949 this out of scope list on your own and 00:30:43.949 --> 00:31:13.521 then I will highlight a few items. Just 00:31:13.521 --> 00:31:35.216 a little more time okay. Now I am going 00:31:35.216 --> 00:31:37.876 to go to the next slide. So we now have 00:31:37.876 --> 00:31:44.618 an out of scope latest hits. So items 00:31:44.618 --> 00:31:48.502 that are out of scope of the Chinese 00:31:48.502 --> 00:31:51.632 wooden bedroom furniture antidumping 00:31:51.632 --> 00:31:57.764 case are seating, mattresses, mattress 00:31:57.764 --> 00:32:03.247 supports, cribs, waterbeds, Bhutans, 00:32:03.247 --> 00:32:07.966 Bhutan frames, office furniture such as 00:32:07.966 --> 00:32:10.387 desks, cabinets, filing cabinets, 00:32:10.387 --> 00:32:13.408 credenza's, and bookcases. Dining room 00:32:13.408 --> 00:32:15.258 or kitchen furniture, furniture 00:32:15.258 --> 00:32:21.220 primarily made of plaiting material, 00:32:21.220 --> 00:32:26.919 things that are woven like reads, bamboo 00:32:26.919 --> 00:32:29.823 furniture, Bentwood furniture, jewelry 00:32:29.823 --> 00:32:35.814 armories, cheval mirrors, and metal bed 00:32:35.814 --> 00:32:38.376 side rails when sold separately. I will 00:32:38.376 --> 00:32:40.626 highlight a few of the out of scope 00:32:40.626 --> 00:32:42.745 items.If 00:32:42.745 --> 00:32:44.995 the jewelry armories doesn't have all of 00:32:44.995 --> 00:32:47.147 the listed characteristics, it isn't an 00:32:47.147 --> 00:32:53.321 excluded jewelry armories. So they are 00:32:53.321 --> 00:32:56.668 very specific about the mentions, the 00:32:56.668 --> 00:32:59.121 drawers, that they are lined with belt, 00:32:59.121 --> 00:33:04.353 that it is felt like, a flip top inset 00:33:04.353 --> 00:33:06.468 mirror, very, very specific about what 00:33:06.468 --> 00:33:14.033 an excluded jewelry armorie is. This is 00:33:14.033 --> 00:33:17.416 another out of scope detail. This is a 00:33:17.416 --> 00:33:19.983 typical cheval mirror. A cheval mirror 00:33:19.983 --> 00:33:23.383 is floor standing and it is typically at 00:33:23.383 --> 00:33:29.352 least 50 inches tall.This 00:33:29.352 --> 00:33:30.312 slide says the furniture parts that 00:33:30.312 --> 00:33:34.728 don't possess the essential character of 00:33:34.728 --> 00:33:37.272 wooden bedroom furniture are outside of 00:33:37.272 --> 00:33:42.101 the antidumping scope. We will talk 00:33:42.101 --> 00:33:44.545 about this and give an example of that 00:33:44.545 --> 00:33:48.349 later. There is a notable change 00:33:48.349 --> 00:33:50.537 circumstance review win this case 00:33:50.537 --> 00:33:53.144 started. It included Murphy beds and 00:33:53.144 --> 00:33:55.299 then there was a change to a 00:33:55.299 --> 00:33:57.975 circumstantial review and it was 00:33:57.975 --> 00:33:59.518 determined that Murphy beds are out of 00:33:59.518 --> 00:34:06.618 scope. So how to look up and 00:34:06.618 --> 00:34:09.832 antidumping or countervailing scope 00:34:09.832 --> 00:34:17.735 ruling? Step 1, go to the ITA/DOC main 00:34:17.735 --> 00:34:20.361 AD CVD page and select a country from 00:34:20.361 --> 00:34:22.504 the drop-down menu. I selected "China." 00:34:22.504 --> 00:34:34.375 Step 2, select the relevant AD CVD case. 00:34:34.375 --> 00:34:40.298 I selected A-570-890 which returned a 00:34:40.298 --> 00:34:43.932 list of scope rulings. You will notice 00:34:43.932 --> 00:34:46.478 that some provided barcode numbers and 00:34:46.478 --> 00:34:49.057 others are hyperlinked. Some have a 00:34:49.057 --> 00:34:51.493 barcode number and others are blue 00:34:51.493 --> 00:34:58.795 hyperlinks. Step 3, if the text is blue 00:34:58.795 --> 00:35:02.288 select the link to download the PDF. If 00:35:02.288 --> 00:35:05.612 the text is not blue then go to this 00:35:05.612 --> 00:35:10.687 website. You will need to make an 00:35:10.687 --> 00:35:13.946 account, except the terms and login. 00:35:13.946 --> 00:35:17.916 And then at the top right of the screen, 00:35:17.916 --> 00:35:21.523 select "barcode" like you see here at 00:35:21.523 --> 00:35:23.581 the bottom, and put the barcode number 00:35:23.581 --> 00:35:26.743 from the previous slide — here is the 00:35:26.743 --> 00:35:32.851 barcode number — and select the "quick 00:35:32.851 --> 00:35:35.367 search" button to download the scope 00:35:35.367 --> 00:35:36.623 ruling.I've 00:35:36.623 --> 00:35:37.591 also asked that all the participants 00:35:37.591 --> 00:35:45.486 receive a one-page document that has 00:35:45.486 --> 00:35:48.989 these slides showing how to do this. I 00:35:48.989 --> 00:35:51.196 don't know if that is going to function. 00:35:51.196 --> 00:35:53.730 So again, if you don't have it in the 00:35:53.730 --> 00:35:56.165 next few or several days, feel free to 00:35:56.165 --> 00:35:58.786 send me an email and I will send it out 00:35:58.786 --> 00:36:11.942 to you.I 00:36:11.942 --> 00:36:13.766 have included some scope rulings of 00:36:13.766 --> 00:36:16.298 interest in this presentation. This 00:36:16.298 --> 00:36:18.563 particular antidumping case must have 50 00:36:18.563 --> 00:36:20.742 plus scope rulings and many of these 00:36:20.742 --> 00:36:25.352 offer multiple pieces of furniture. In 00:36:25.352 --> 00:36:28.215 the scope ruling the fully upholstered 00:36:28.215 --> 00:36:29.493 wooden platform it was determined to be 00:36:29.493 --> 00:36:32.376 outside of the wooden bedroom furniture 00:36:32.376 --> 00:36:36.151 scope. The headboard is upholstered, 00:36:36.151 --> 00:36:38.754 the sideboards are upholstered. The 00:36:38.754 --> 00:36:41.180 only thing that is not upholstered are 00:36:41.180 --> 00:36:44.810 the wood slats and the legs. And it 00:36:44.810 --> 00:36:46.956 was determined to be outside of the 00:36:46.956 --> 00:36:51.150 wooden bedroom furniture scope. Next, 00:36:51.150 --> 00:36:53.873 certain baby changing stations are out 00:36:53.873 --> 00:36:58.945 of scope. In these scope rulings, baby 00:36:58.945 --> 00:37:00.857 changing stations that didn't have 00:37:00.857 --> 00:37:04.957 sufficient space for storing clothing 00:37:04.957 --> 00:37:07.067 were determined to be out of scope. The 00:37:07.067 --> 00:37:10.589 first example has no drawers and the 00:37:10.589 --> 00:37:13.311 second example has one shallow drawer 00:37:13.311 --> 00:37:14.845 and the third example has drawers, but 00:37:14.845 --> 00:37:20.357 they are made of cloth.Perhaps 00:37:20.357 --> 00:37:21.631 it is self-evident that nonveteran 00:37:21.631 --> 00:37:25.030 furniture is out of scope of the Chinese 00:37:25.030 --> 00:37:31.333 wooden bedroom furniture case. 00:37:31.333 --> 00:37:34.590 Medicine cabinets, linen towers, 00:37:34.590 --> 00:37:37.339 bathroom space savers, hampers, this one 00:37:37.339 --> 00:37:39.644 with a tilt door, were all determined to 00:37:39.644 --> 00:37:41.864 be out of scope. And this is the 00:37:41.864 --> 00:37:47.219 barcode number. The following infant 00:37:47.219 --> 00:37:50.984 organizer was in scope. This infant 00:37:50.984 --> 00:37:54.160 organizer was in scope although it has 00:37:54.160 --> 00:37:56.704 drawers, the shelves are sufficiently 00:37:56.704 --> 00:37:59.604 large to hold clothing and it is part of 00:37:59.604 --> 00:38:02.787 a four piece nursery set that includes a 00:38:02.787 --> 00:38:10.414 crib and a baby changing table.All 00:38:10.414 --> 00:38:13.598 chest such as these are out of scope. 00:38:13.598 --> 00:38:18.724 They are a hall chest and not bedroom 00:38:18.724 --> 00:38:21.771 furniture because they are more ornate, 00:38:21.771 --> 00:38:23.611 not expensive, advertised and displayed 00:38:23.611 --> 00:38:29.336 as a hall chest, not as deep as a 00:38:29.336 --> 00:38:32.484 typical bedroom chest, part of a 00:38:32.484 --> 00:38:36.062 coordinated non-bedroom furniture set. 00:38:36.062 --> 00:38:38.403 The scope excludes parts that don't have 00:38:38.403 --> 00:38:40.148 the character of wooden furniture. 00:38:40.148 --> 00:38:43.425 This is what I mentioned before a 00:38:43.425 --> 00:38:49.723 urethane footboard basis are used to 00:38:49.723 --> 00:38:51.548 support footboard bedposts. Here's a 00:38:51.548 --> 00:38:57.611 picture of a urethane footboard base and 00:38:57.611 --> 00:39:02.999 here is where it goes, at the base of 00:39:02.999 --> 00:39:06.519 the four corners of this bed. They are 00:39:06.519 --> 00:39:09.409 made primarily of painted urethane with 00:39:09.409 --> 00:39:11.559 internal wood components.So 00:39:11.559 --> 00:39:13.340 if you were to see a cross-section of 00:39:13.340 --> 00:39:14.924 this, you would see there is a wooden 00:39:14.924 --> 00:39:17.564 piece on the inside, and it is 00:39:17.564 --> 00:39:22.111 completely encased in the plastic that 00:39:22.111 --> 00:39:23.312 is urethane; however, there is no 00:39:23.312 --> 00:39:24.306 exposed wood. The urethane base does 00:39:24.306 --> 00:39:30.475 not — the out of scope determination 00:39:30.475 --> 00:39:32.550 said the urethane base does not possess 00:39:32.550 --> 00:39:35.118 the essential character of wooden 00:39:35.118 --> 00:39:37.122 bedroom furniture. It is a relatively 00:39:37.122 --> 00:39:43.916 minor bed part. It is not a key 00:39:43.916 --> 00:39:51.164 distinguished feature of a bed.This 00:39:51.164 --> 00:39:54.157 is how wooden bedroom furniture appears 00:39:54.157 --> 00:39:55.557 in the tariff. Classification of 00:39:55.557 --> 00:39:56.709 wooden bedroom furniture is relatively 00:39:56.709 --> 00:40:03.952 straightforward., either it is a bed in 00:40:03.952 --> 00:40:11.365 9403.50.90.45 or it is "other" in 00:40:11.365 --> 00:40:13.400 9403.50.90.80. And of course the number 00:40:13.400 --> 00:40:15.154 2 subscript tells us if it is Chinese 00:40:15.154 --> 00:40:19.294 then there is 25% section 301 duties. 00:40:19.294 --> 00:40:21.733 Or there is the club's occasion of 00:40:21.733 --> 00:40:25.891 wooden bedroom parts. As we saw the 00:40:25.891 --> 00:40:31.367 scope for — the scope includes parts 00:40:31.367 --> 00:40:33.564 with the essential character of wooden 00:40:33.564 --> 00:40:34.775 bedroom furniture and they would go 00:40:34.775 --> 00:40:39.460 here. That concludes wooden bedroom 00:40:39.460 --> 00:40:41.154 furniture, and now we are going to move 00:40:41.154 --> 00:40:53.464 onto the boltless steel steel shelving. 00:40:53.464 --> 00:40:56.519 Boltless steel shelving is retail 00:40:56.519 --> 00:40:58.724 package, assembled primarily without the 00:40:58.724 --> 00:41:01.756 use of nuts, bolts, or screws, assembled 00:41:01.756 --> 00:41:06.103 by methods such as a fitting a rivet tab 00:41:06.103 --> 00:41:08.588 or other connector on one support into a 00:41:08.588 --> 00:41:11.736 hole, slot, or similar receptacle on 00:41:11.736 --> 00:41:14.006 another. The support logs together to 00:41:14.006 --> 00:41:15.976 form a frame and provide structural 00:41:15.976 --> 00:41:17.253 integrity without the inclusion of any 00:41:17.253 --> 00:41:20.690 decking. Incidental use of nuts, bolts, 00:41:20.690 --> 00:41:23.762 or screws to accessories, wall anchors, 00:41:23.762 --> 00:41:25.754 tie bars, or shelf supports is 00:41:25.754 --> 00:41:28.783 immaterial. It includes add-on kits 00:41:28.783 --> 00:41:31.857 used to add an extension to the shelving 00:41:31.857 --> 00:41:38.352 unit. It does not include parts or 00:41:38.352 --> 00:41:47.694 made to order shelving.Here 00:41:47.694 --> 00:41:49.693 are two typical styles of boltless steel 00:41:49.693 --> 00:41:52.627 shelving. One has a particleboard deck 00:41:52.627 --> 00:41:55.473 and the other with a wire deck. The 00:41:55.473 --> 00:42:03.167 next slide is a close-up showing the 00:42:03.167 --> 00:42:04.984 boltless construction. Sometimes it is 00:42:04.984 --> 00:42:06.769 called rivet shelves, and we can see 00:42:06.769 --> 00:42:10.959 why. This shows the key hole punch out 00:42:10.959 --> 00:42:13.436 on the upright column and the rivets are 00:42:13.436 --> 00:42:15.215 on the horizontal supports. Now that we 00:42:15.215 --> 00:42:17.246 have a mental image, we can return to 00:42:17.246 --> 00:42:23.558 the scope. The following factors are 00:42:23.558 --> 00:42:27.439 immaterial. Vertical support or post 00:42:27.439 --> 00:42:29.778 type, doesn't matter what kind of 00:42:29.778 --> 00:42:33.315 vertical support or post is used. 00:42:33.315 --> 00:42:38.029 Horizontal support or beam/brace 00:42:38.029 --> 00:42:42.394 profile. It doesn't matter if it is a 00:42:42.394 --> 00:42:44.113 Z-beam, C-beam, L-beam, etc. And number 00:42:44.113 --> 00:42:47.192 of supports is a material. The surface 00:42:47.192 --> 00:42:50.908 coating, if it is painted, if it is 00:42:50.908 --> 00:42:54.430 epoxy, powder coating, immaterial. And 00:42:54.430 --> 00:42:55.276 the number shelves and the weight 00:42:55.276 --> 00:43:02.988 capacity.The 00:43:02.988 --> 00:43:04.773 following slide list additional factors 00:43:04.773 --> 00:43:10.295 that are explicitly irrelevant. Shape, 00:43:10.295 --> 00:43:12.676 including but not limited to rectangle 00:43:12.676 --> 00:43:16.284 or, square, and corner units; decking 00:43:16.284 --> 00:43:18.577 materials, including but not limited to 00:43:18.577 --> 00:43:21.241 wire decking, particleboard, laminated 00:43:21.241 --> 00:43:23.866 board, or no deck at all; or the 00:43:23.866 --> 00:43:25.586 boltless method by which vertical and 00:43:25.586 --> 00:43:27.847 horizontal supports connect, including 00:43:27.847 --> 00:43:30.021 but not limited to keyhole and rivet, 00:43:30.021 --> 00:43:32.965 slot and tab, welded frame, punched 00:43:32.965 --> 00:43:35.619 rivet, and clip. They are all 00:43:35.619 --> 00:43:38.972 immaterial.Cantilever 00:43:38.972 --> 00:43:41.548 boltless steel shelving is also in 00:43:41.548 --> 00:43:48.596 scope. These are two examples. 00:43:48.596 --> 00:43:52.577 Boltless shelving units with bins are in 00:43:52.577 --> 00:43:54.528 scope. Boltless shelving units with the 00:43:54.528 --> 00:43:58.588 wheels are scope.Here 00:43:58.588 --> 00:44:01.950 is a close-up of some common decking 00:44:01.950 --> 00:44:04.333 materials. Particleboard, wire, and 00:44:04.333 --> 00:44:07.037 steel are all possible decking 00:44:07.037 --> 00:44:09.072 materials. What is explicitly excluded 00:44:09.072 --> 00:44:13.113 from the scope? While-mounted 00:44:13.113 --> 00:44:16.658 shelving, wire shelving, bulk-packed 00:44:16.658 --> 00:44:22.734 parts or components, made-to-order 00:44:22.734 --> 00:44:33.521 shelving systems. What does boltless 00:44:33.521 --> 00:44:36.160 wall-mounted shelving look like? It is 00:44:36.160 --> 00:44:38.611 defined as a shelving on the wall and 00:44:38.611 --> 00:44:42.163 does not stand on or transfer load to 00:44:42.163 --> 00:44:44.284 the floor. These are explicitly 00:44:44.284 --> 00:44:52.569 excluded.Wire 00:44:52.569 --> 00:44:54.766 shelving units are explicitly excluded. 00:44:54.766 --> 00:44:56.610 They consist of wire shelves that 00:44:56.610 --> 00:44:59.540 incorporate both a wire deck and wire 00:44:59.540 --> 00:45:03.747 horizontal supports. Here we see a wire 00:45:03.747 --> 00:45:06.404 deck and here on the side all the wire 00:45:06.404 --> 00:45:08.889 horizontal supports in a single piece 00:45:08.889 --> 00:45:13.372 with tubular collars the slide over the 00:45:13.372 --> 00:45:15.579 vertical posts and onto the plastic 00:45:15.579 --> 00:45:18.712 sleeves that are snapped onto the posts. 00:45:18.712 --> 00:45:22.393 Here we have it up close, and here, we 00:45:22.393 --> 00:45:27.144 have the assembly operation.The 00:45:27.144 --> 00:45:29.112 following shelving is excluded by the 00:45:29.112 --> 00:45:33.503 definition but not explicitly. Here we 00:45:33.503 --> 00:45:38.531 have open file shelving, bookcase, and 00:45:38.531 --> 00:45:40.164 storage cabinet. You will notice that 00:45:40.164 --> 00:45:42.347 we have no horizontal or vertical beams 00:45:42.347 --> 00:45:46.193 for support. You notice that the 00:45:46.193 --> 00:45:49.379 support is provided by the opbox design 00:45:49.379 --> 00:45:52.036 and by the shelving. We see that the 00:45:52.036 --> 00:45:54.412 shelving is not supported by beams or 00:45:54.412 --> 00:45:59.722 braces. The shelving is not supported — 00:45:59.722 --> 00:46:05.311 is not a supported "deck." So these are 00:46:05.311 --> 00:46:15.905 outside of scope. If you are looking 00:46:15.905 --> 00:46:20.248 for a surety that they are out of scope 00:46:20.248 --> 00:46:25.559 you can go to the ITA/DOC website to 00:46:25.559 --> 00:46:27.742 read the exclusion. This slide shows us 00:46:27.742 --> 00:46:31.016 the scope ruling on the ITA/DOC website. 00:46:31.016 --> 00:46:34.619 We have only six scope rulings and the 00:46:34.619 --> 00:46:36.368 cabinets on the previous slide are 00:46:36.368 --> 00:46:43.894 similar to those in the first barcode 00:46:43.894 --> 00:46:47.191 356-5332-01. On the next slide we see 00:46:47.191 --> 00:46:52.500 this one, the 21 shoe and utility rack 00:46:52.500 --> 00:47:00.146 frames. Looking up the request, the 00:47:00.146 --> 00:47:02.097 racks are determined to be out of scope 00:47:02.097 --> 00:47:03.947 because one, the shelves are necessary 00:47:03.947 --> 00:47:06.534 to provide the unit structural integrity 00:47:06.534 --> 00:47:08.345 and two, the shelves don't lock into 00:47:08.345 --> 00:47:12.667 place, but twist into place.Let's 00:47:12.667 --> 00:47:18.547 talk about the loophole. Remember the 00:47:18.547 --> 00:47:20.305 shelving unit has to be packaged for 00:47:20.305 --> 00:47:24.565 sale to be within scope. When you read 00:47:24.565 --> 00:47:27.721 antidumping scope orders, remember that 00:47:27.721 --> 00:47:29.941 they are written by US industry was 00:47:29.941 --> 00:47:32.003 something very particular in mind. They 00:47:32.003 --> 00:47:34.159 write the scope to bit their business 00:47:34.159 --> 00:47:36.610 needs even if it doesn't appear to make 00:47:36.610 --> 00:47:38.863 a lot of sense. In this case, it 00:47:38.863 --> 00:47:41.785 appears to me that the US petitioner 00:47:41.785 --> 00:47:45.787 wants to reduce importations of the 00:47:45.787 --> 00:47:48.196 packaged Chinese boltless steel 00:47:48.196 --> 00:47:49.815 shelving, but has an issue with the 00:47:49.815 --> 00:47:51.968 parts. This is how it looks in the 00:47:51.968 --> 00:47:54.916 tariff schedule. Classification for 00:47:54.916 --> 00:48:02.416 boltless steel shelving is in 00:48:02.416 --> 00:48:04.040 9403.20.00.75. It is classified here 00:48:04.040 --> 00:48:06.772 that it is made in China and that it is 00:48:06.772 --> 00:48:14.147 subject to A 0578 and C0579. And you 00:48:14.147 --> 00:48:16.701 know what the number 2 superscript is? 00:48:16.701 --> 00:48:23.069 Let's look briefly at the reference to 00:48:23.069 --> 00:48:25.549 the statistical note two in Chapter 00:48:25.549 --> 00:48:29.563 4.For 00:48:29.563 --> 00:48:35.322 the purposes of statistical note number 00:48:35.322 --> 00:48:37.628 9403.20.0075, the term "boltless or 00:48:37.628 --> 00:48:42.664 press-fit steel shelving units 00:48:42.664 --> 00:48:45.540 prepackaged for sale" this wording 00:48:45.540 --> 00:48:51.234 matches the wording in the scope. If 00:48:51.234 --> 00:48:54.333 the article meets this very specific 00:48:54.333 --> 00:48:56.517 definition that we have been discussing, 00:48:56.517 --> 00:49:02.001 it is classified in 9403.20.0075 and if 00:49:02.001 --> 00:49:04.842 it is from China, it is subject to 00:49:04.842 --> 00:49:09.313 antidumping and countervailing duty.If 00:49:09.313 --> 00:49:12.837 it doesn't meet this definition, 00:49:12.837 --> 00:49:15.266 remember the wire racks supported by 00:49:15.266 --> 00:49:17.339 plastic Culver's, if it is a steel rack, 00:49:17.339 --> 00:49:19.987 but it does not meet the very specific 00:49:19.987 --> 00:49:23.159 distance will note two definition and 00:49:23.159 --> 00:49:24.313 classified here in statistical suffix AD 00:49:24.313 --> 00:49:29.686 two. This concludes boltless steel 00:49:29.686 --> 00:49:31.008 shelving.Never 00:49:31.008 --> 00:49:33.165 going to look at heavy-duty steel racks 00:49:33.165 --> 00:49:37.774 and parts thereof.As 00:49:37.774 --> 00:49:39.526 consumers we are probably not familiar 00:49:39.526 --> 00:49:42.600 with the steel racks, the subject of 00:49:42.600 --> 00:49:46.143 these ACPD cases. The actual case name 00:49:46.143 --> 00:49:49.077 is steel racks and parts thereof. I 00:49:49.077 --> 00:49:55.186 have inserted the "heavy-duty" for 00:49:55.186 --> 00:49:57.924 understanding. Articles will most 00:49:57.924 --> 00:50:00.337 likely be placed on and removed from 00:50:00.337 --> 00:50:04.564 these racks by forklifts. Here is what 00:50:04.564 --> 00:50:06.645 these things typically look like. You 00:50:06.645 --> 00:50:10.282 can see these are very heavy-duty, 00:50:10.282 --> 00:50:13.827 load-bearing members with a width and 00:50:13.827 --> 00:50:14.882 depth greater than 2 inches. 00:50:14.882 --> 00:50:17.998 Load-bearing member with yield strength 00:50:17.998 --> 00:50:23.626 greater than or equal to 36,000 pounds 00:50:23.626 --> 00:50:27.145 per square inch. The load-bearing 00:50:27.145 --> 00:50:31.138 members are at least 0.044 inches 00:50:31.138 --> 00:50:39.737 thick.This 00:50:39.737 --> 00:50:45.215 flex steel scope ruling, and here is the 00:50:45.215 --> 00:50:49.140 access barcode number here, it is 00:50:49.140 --> 00:50:51.820 excellent. It has dozens of pictures of 00:50:51.820 --> 00:50:54.718 many types of beams and fasteners and 00:50:54.718 --> 00:50:57.211 accessories. It is very informative. I 00:50:57.211 --> 00:51:02.435 encourage you to look at it if these two 00:51:02.435 --> 00:51:06.519 ADCP cases are of interest to you.Next, 00:51:06.519 --> 00:51:07.193 articles that are explicitly excluded 00:51:07.193 --> 00:51:13.110 from the scope. Decks, wire shelving 00:51:13.110 --> 00:51:16.894 units, fasteners, non-steel components, 00:51:16.894 --> 00:51:18.989 article subject to the boltless steel 00:51:18.989 --> 00:51:22.646 shelving case, while-mounted and 00:51:22.646 --> 00:51:25.991 ceiling-mounted shelving and racks, 00:51:25.991 --> 00:51:28.458 scaffolding that complies with certain 00:51:28.458 --> 00:51:30.606 safety requirements; remember these are 00:51:30.606 --> 00:51:33.948 all out of scope — tubular racks such as 00:51:33.948 --> 00:51:36.342 garment racks and drying racks; portable 00:51:36.342 --> 00:51:39.243 tear racks that meet certain 00:51:39.243 --> 00:51:41.410 requirements including: Easily 00:51:41.410 --> 00:51:43.725 removable corner pieces, assembly 00:51:43.725 --> 00:51:46.620 without bolts, braces, anchors, 00:51:46.620 --> 00:51:49.225 connectors etc., no interlocking 00:51:49.225 --> 00:51:54.144 mechanisms, and four, no anchoring 00:51:54.144 --> 00:51:56.625 assembly. Those are all out of scope as 00:51:56.625 --> 00:51:58.187 are accessories that are bolted to the 00:51:58.187 --> 00:52:02.793 floor and not attached to the rack, that 00:52:02.793 --> 00:52:10.056 is column protectors, corner guardsThose 00:52:10.056 --> 00:52:14.126 are explicitly out of scope. So what 00:52:14.126 --> 00:52:16.091 does this look like in the tariff 00:52:16.091 --> 00:52:24.336 schedule? Here we have it, 9403. to 00:52:24.336 --> 00:52:27.324 0.00. AD two, steel racks, other than 00:52:27.324 --> 00:52:33.951 those described in statistical suffix 00:52:33.951 --> 00:52:40.184 75. This is where the boltless racks 00:52:40.184 --> 00:52:50.099 are. 9403.99.90.40 are four parts of 00:52:50.099 --> 00:52:56.769 racks 9403. to 0.00 AD two. That 00:52:56.769 --> 00:52:58.357 concludes heavy-duty steel racks and 00:52:58.357 --> 00:53:00.234 parts thereof. Now we will look at the 00:53:00.234 --> 00:53:02.366 storage lockers. I think we all went to 00:53:02.366 --> 00:53:04.344 high school or have gone to a gymnasium 00:53:04.344 --> 00:53:06.211 and are familiar with metal storage 00:53:06.211 --> 00:53:08.844 lockers and the following slides tell us 00:53:08.844 --> 00:53:16.909 what is in scope. Metal lockers with or 00:53:16.909 --> 00:53:20.841 without doors and parts thereof with 00:53:20.841 --> 00:53:23.159 outer dimensions less than 27 inches 00:53:23.159 --> 00:53:26.290 wide and less then 27 inches deep. 00:53:26.290 --> 00:53:29.372 Configured for use with a lock or locking 00:53:29.372 --> 00:53:33.603 mechanism or packaged with one. They 00:53:33.603 --> 00:53:35.077 are floor standing, they can be 00:53:35.077 --> 00:53:37.923 installed on a base, they can be 00:53:37.923 --> 00:53:39.115 wall-mounted. They can be assembled or 00:53:39.115 --> 00:53:43.715 disassembled. And also all parts and 00:53:43.715 --> 00:53:47.309 components made from flat-rolled metal 00:53:47.309 --> 00:53:51.989 or expanded metal doors, frames, 00:53:51.989 --> 00:53:56.123 shelves, tops, bottoms,, etc. and 00:53:56.123 --> 00:53:58.813 imported with lockers or separately. 00:53:58.813 --> 00:54:08.785 Those are all in scope.So 00:54:08.785 --> 00:54:11.600 what is out of scope? Lockers of any 00:54:11.600 --> 00:54:16.344 nonmetallic material, exchange lockers — 00:54:16.344 --> 00:54:18.594 these are lockers with multiple 00:54:18.594 --> 00:54:21.511 individual locking doors mounted on one 00:54:21.511 --> 00:54:22.855 master locking door to access multiple 00:54:22.855 --> 00:54:30.173 units. If you ever go to a place like 00:54:30.173 --> 00:54:32.107 Mailboxes Plus where they can go in the 00:54:32.107 --> 00:54:33.574 back and hold all of the male in the 00:54:33.574 --> 00:54:35.578 back but for you to take your mail out 00:54:35.578 --> 00:54:38.530 you have an individual locked door, that 00:54:38.530 --> 00:54:41.635 would be an exchange locker.Metal 00:54:41.635 --> 00:54:44.594 lockers imported with an installed 00:54:44.594 --> 00:54:47.971 electronic, Internet-enabled lock that 00:54:47.971 --> 00:54:49.744 permits communication between the LOC 00:54:49.744 --> 00:54:52.950 and other Internet connected devices. I 00:54:52.950 --> 00:54:56.142 think this is likely lockers for Amazon 00:54:56.142 --> 00:54:59.684 that you have in the grocery store. 00:54:59.684 --> 00:55:02.529 Wire mesh lockers with all of the 00:55:02.529 --> 00:55:04.599 following characteristics: At least 00:55:04.599 --> 00:55:07.312 three sites, including the door, made 00:55:07.312 --> 00:55:10.531 from wire mesh; and the width and depth 00:55:10.531 --> 00:55:13.540 exceed 25 inches and the height exceeds 00:55:13.540 --> 00:55:21.450 90 inches.Here 00:55:21.450 --> 00:55:28.173 is what this looks like in the HTSUS. 00:55:28.173 --> 00:55:33.104 9403. to 0.00.78. Storage lockers other 00:55:33.104 --> 00:55:35.585 than exchange lockers and there is a 00:55:35.585 --> 00:55:37.674 very good description of exchange 00:55:37.674 --> 00:55:45.060 lockers in statistical note three.So 00:55:45.060 --> 00:55:50.303 now we have moved on to Chinese and 00:55:50.303 --> 00:55:57.898 Vietnamese tool chest and cabinets. 00:55:57.898 --> 00:55:59.712 These typically look something like this. 00:55:59.712 --> 00:56:03.372 This is not something you would carry 00:56:03.372 --> 00:56:05.967 in your hand. This is something that is 00:56:05.967 --> 00:56:08.231 going to be on wheels or is going to be 00:56:08.231 --> 00:56:10.879 a separate piece that sits on top of a 00:56:10.879 --> 00:56:21.243 wheeled piece. So in scope, certain 00:56:21.243 --> 00:56:24.773 metal tool chest and tool cabinets, with 00:56:24.773 --> 00:56:26.417 drawers including top chest, 00:56:26.417 --> 00:56:28.510 intermediate chest, tool cabinets, and 00:56:28.510 --> 00:56:30.762 side cabinets, storage units, mobile 00:56:30.762 --> 00:56:32.761 workbenches, and workstations with the 00:56:32.761 --> 00:56:35.521 following characteristics: They must 00:56:35.521 --> 00:56:38.576 have a metal body, each unit has two or 00:56:38.576 --> 00:56:40.777 more drawers, the width has to be 00:56:40.777 --> 00:56:43.348 greater than 15 inches for the side 00:56:43.348 --> 00:56:45.401 cabinets and greater than 21 inches for 00:56:45.401 --> 00:56:48.977 all other cabinets, but may not exceed 00:56:48.977 --> 00:56:51.184 60 inches. The depth has to be greater 00:56:51.184 --> 00:56:55.337 than 10 inches but not exceed 24 inches. 00:56:55.337 --> 00:56:58.460 It must be prepackaged for retail sale 00:56:58.460 --> 00:57:01.017 and they may have doors, shelves, 00:57:01.017 --> 00:57:06.367 handles, and a worksurface.Out 00:57:06.367 --> 00:57:11.373 of scope — these were in scope and now 00:57:11.373 --> 00:57:14.013 out of scope or service carts, a body 00:57:14.013 --> 00:57:17.113 made of steel that is greater than 18 00:57:17.113 --> 00:57:25.287 gauge or thinner, and the weight to with 00:57:25.287 --> 00:57:27.227 a ratio greater than certain indicated 00:57:27.227 --> 00:57:32.224 weights. So 18 or 20 gauge is out of 00:57:32.224 --> 00:57:37.566 scope. What does this look like in the 00:57:37.566 --> 00:57:47.938 tariff schedule? 9403.20.00.90. Other 00:57:47.938 --> 00:57:50.342 furniture and parts thereof, other metal 00:57:50.342 --> 00:57:53.745 furniture, other, other, other. That 00:57:53.745 --> 00:57:56.398 concludes tool chest and cabinets. Next 00:57:56.398 --> 00:58:00.981 to metal file and cabinets.I 00:58:00.981 --> 00:58:02.154 think we are all familiar with lateral 00:58:02.154 --> 00:58:03.986 and vertical filing cabinets. This is 00:58:03.986 --> 00:58:07.585 not a very big case. I have it on just 00:58:07.585 --> 00:58:09.918 two slides. The scope said it doesn't 00:58:09.918 --> 00:58:12.276 matter whether there are wheels, 00:58:12.276 --> 00:58:14.802 non-file drawers, copies or accessories 00:58:14.802 --> 00:58:17.653 such as hanging files, rails, folders, 00:58:17.653 --> 00:58:21.931 or the state of assembly. How it looks 00:58:21.931 --> 00:58:27.702 in the tariff schedule. There it is. 00:58:27.702 --> 00:58:32.309 9403.10.20. It could not be any 00:58:32.309 --> 00:58:34.914 plainer. Of course the number 2 00:58:34.914 --> 00:58:37.324 superscript tells us about the section 00:58:37.324 --> 00:58:42.774 301 duties.As 00:58:42.774 --> 00:58:44.839 consumers, we are all familiar with 00:58:44.839 --> 00:58:50.153 ironing boards. In scope ironing boards 00:58:50.153 --> 00:58:52.272 are floor standing, they have a metal 00:58:52.272 --> 00:58:56.947 top, it can be with or without a pad or 00:58:56.947 --> 00:58:59.869 cover, they can be complete or 00:58:59.869 --> 00:59:02.621 incomplete, they can be assembled or 00:59:02.621 --> 00:59:04.372 unassembled, or it can be there parts, 00:59:04.372 --> 00:59:08.572 all of those things are in scope.Out 00:59:08.572 --> 00:59:13.592 of scope, countertop and wall-mounted 00:59:13.592 --> 00:59:17.139 models are out of scope. So down below 00:59:17.139 --> 00:59:21.465 we have pictures of one in scope ironing 00:59:21.465 --> 00:59:23.897 board and two out of scope ironing 00:59:23.897 --> 00:59:31.745 boards. Here's how it looks in the 00:59:31.745 --> 00:59:33.439 tariff schedule. It could not be a 00:59:33.439 --> 00:59:48.893 cleaner number, 9403.2.00.11 for the 00:59:48.893 --> 00:59:50.414 ironing board. Here are the parts. It 00:59:50.414 --> 00:59:58.181 is "other." It is "other, other."All 00:59:58.181 --> 01:00:01.262 articles classified in any 9403 that are 01:00:01.262 --> 01:00:03.921 of Chinese origin are subject to an 01:00:03.921 --> 01:00:09.795 additional 25% section 301 duty with the 01:00:09.795 --> 01:00:12.231 exception of, I think you have noticed 01:00:12.231 --> 01:00:13.767 there have been a whole lot of those 01:00:13.767 --> 01:00:17.217 superscript two. The only exception is 01:00:17.217 --> 01:00:22.694 plastic furniture, 9403.70. And that is 01:00:22.694 --> 01:00:28.089 the only subheading that is not subject 01:00:28.089 --> 01:00:32.371 to Chinese section 301 duties of 25% and 01:00:32.371 --> 01:00:36.950 had a number 9403. There are currently 01:00:36.950 --> 01:00:40.168 seven section 301 exclusions in 9403 and 01:00:40.168 --> 01:00:42.792 9404. Previously there was as many as 01:00:42.792 --> 01:00:45.975 16.When 01:00:45.975 --> 01:00:50.603 we look at heading 9404, articles and 01:00:50.603 --> 01:00:54.991 heading 9404 are free of Chinese section 01:00:54.991 --> 01:00:57.511 301 duties with the following exception. 01:00:57.511 --> 01:01:04.711 Mattress supports, a.k.a. box springs 01:01:04.711 --> 01:01:08.519 in 9404.10 have 25% section 301 duties, 01:01:08.519 --> 01:01:14.512 as do mattresses and mattress inner 01:01:14.512 --> 01:01:17.708 springs. So it doesn't matter if they 01:01:17.708 --> 01:01:21.224 are phone or spring or if they are the 01:01:21.224 --> 01:01:24.494 naked inter-springs, they all have the 01:01:24.494 --> 01:01:28.325 25% section 301 duty if they are 01:01:28.325 --> 01:01:33.415 Chinese. Also we have a 7.5% section 01:01:33.415 --> 01:01:36.156 301 duty on Chinese pillows and cushions 01:01:36.156 --> 01:01:37.912 which are classified in 01:01:37.912 --> 01:01:47.220 9404.90.10/20.There 01:01:47.220 --> 01:01:49.227 are two section 301 exclusions that I 01:01:49.227 --> 01:01:56.893 would like to address. High-pressure 01:01:56.893 --> 01:02:01.890 laminated bamboo furniture in Chinese 01:02:01.890 --> 01:02:05.075 Section 301. There is a very narrow 01:02:05.075 --> 01:02:06.511 Section 301 exclusion for high-pressure 01:02:06.511 --> 01:02:13.328 laminate, HPL bamboo furniture and it is 01:02:13.328 --> 01:02:16.743 9903. AD 8.67, that allows for the 01:02:16.743 --> 01:02:18.818 importation of certain Chinese bamboo 01:02:18.818 --> 01:02:28.220 furniture classified in 9403.2.0050 and 01:02:28.220 --> 01:02:31.118 9403.82.0015 without the otherwise 01:02:31.118 --> 01:02:36.496 applicable 25% Section 301 duties.The 01:02:36.496 --> 01:02:40.517 merchandise eligible for this Chapter 99 01:02:40.517 --> 01:02:43.277 exclusion is household furniture of 01:02:43.277 --> 01:02:46.355 metal and high-pressure laminated bamboo 01:02:46.355 --> 01:02:54.339 in 9403.2.0050, and household furniture, 01:02:54.339 --> 01:02:57.557 high-pressure laminated bamboo, other 01:02:57.557 --> 01:03:04.891 than babies' or children's furniture in 01:03:04.891 --> 01:03:10.370 9403.82.0015. These are two exclusions 01:03:10.370 --> 01:03:16.778 to the 25% Section 301 duties.Now 01:03:16.778 --> 01:03:20.544 it is for high-pressure laminate bamboo 01:03:20.544 --> 01:03:25.003 furniture, HLP member furniture is made 01:03:25.003 --> 01:03:28.212 from boards, sheets, or other shapes of 01:03:28.212 --> 01:03:31.571 engineered or agglomerated bamboo 01:03:31.571 --> 01:03:36.952 substrate that of been covered in an HLP 01:03:36.952 --> 01:03:39.554 laminate. The aforementioned bamboo is 01:03:39.554 --> 01:03:41.115 made by processes that may include 01:03:41.115 --> 01:03:46.518 agglomeration of strands with resin, 01:03:46.518 --> 01:03:49.102 milling, steaming, drying, in 01:03:49.102 --> 01:03:51.680 organizing, gluing, pressing, and 01:03:51.680 --> 01:04:00.932 subsequent cutting. And so that is how 01:04:00.932 --> 01:04:05.403 the bamboo substrate is made. The after 01:04:05.403 --> 01:04:06.470 mentioned high-pressure laminate is 01:04:06.470 --> 01:04:08.809 produced by saturating multiple layers 01:04:08.809 --> 01:04:16.312 of craft paper with phenolic resin. A 01:04:16.312 --> 01:04:17.342 layer of printed the core paper is 01:04:17.342 --> 01:04:19.967 placed on top of the craft paper before 01:04:19.967 --> 01:04:22.132 pressing. The resulting sandwich is 01:04:22.132 --> 01:04:23.705 fused together under heat and pressure, 01:04:23.705 --> 01:04:25.976 more than 1000 pounds per square inch. 01:04:25.976 --> 01:04:31.487 The thermoset plastic and paper are 01:04:31.487 --> 01:04:34.419 transformed by the curing process into a 01:04:34.419 --> 01:04:37.831 single, rigid laminated sheet.As 01:04:37.831 --> 01:04:43.385 you can see the definition of HPL bamboo 01:04:43.385 --> 01:04:46.728 furniture is very important. We take 01:04:46.728 --> 01:04:48.773 this opportunity to inform the Trade 01:04:48.773 --> 01:04:50.525 community that we have recently become 01:04:50.525 --> 01:04:52.978 aware of substantial importations a 01:04:52.978 --> 01:04:54.680 bamboo furniture classified in 01:04:54.680 --> 01:05:02.578 subheadings 9403.2.0050 and 01:05:02.578 --> 01:05:04.260 9403.82.0015, with the secondary 01:05:04.260 --> 01:05:09.163 classification of 9903. AD 8.67, that 01:05:09.163 --> 01:05:12.601 very likely do not meet the after 01:05:12.601 --> 01:05:13.323 mentioned definition of HPL bamboo 01:05:13.323 --> 01:05:18.769 furniture. And we ask importers to 01:05:18.769 --> 01:05:21.195 review such importations that they have 01:05:21.195 --> 01:05:29.293 made to ensure their eligibility.This 01:05:29.293 --> 01:05:35.735 concludes ABCD Section four headings 01:05:35.735 --> 01:05:37.899 9403 and 9404. I am now available for 01:05:37.899 --> 01:05:43.366 questions. You can type your question 01:05:43.366 --> 01:05:45.740 into the chat. I encourage you to 01:05:45.740 --> 01:05:48.818 continue to request findings and rulings 01:05:48.818 --> 01:05:51.299 and always provide us with the most 01:05:51.299 --> 01:05:53.970 complete information possible when doing 01:05:53.970 --> 01:05:56.173 so. It avoids a lot of back-and-forth. 01:05:56.173 --> 01:05:59.845 Next I will give you a slide that has 01:05:59.845 --> 01:06:02.500 contact information.That 01:06:02.500 --> 01:06:05.341 concludes this presentation for the 01:06:05.341 --> 01:06:06.949 question and answer section. I want to 01:06:06.949 --> 01:06:09.657 give a shout out to our technical team 01:06:09.657 --> 01:06:13.171 for making today's presentation possible 01:06:13.171 --> 01:06:14.847 as well as the transcriber and everyone 01:06:14.847 --> 01:06:17.021 else who works behind the scene. I also 01:06:17.021 --> 01:06:20.974 want to give a shout out to my national 01:06:20.974 --> 01:06:22.940 Import Specialist associate, Alex 01:06:22.940 --> 01:06:25.536 Tsigos. Not a day goes by that he 01:06:25.536 --> 01:06:28.018 doesn't make my workday substantially 01:06:28.018 --> 01:06:29.534 easier. If, for some reason, you wanted 01:06:29.534 --> 01:06:31.324 to watch this webinar again or more 01:06:31.324 --> 01:06:34.760 likely one of our other webinars, they 01:06:34.760 --> 01:06:37.425 can be found at the link provided above. 01:06:37.425 --> 01:06:39.968 And of course I thank you all for your 01:06:39.968 --> 01:06:45.400 time.>>: 01:06:45.400 --> 01:06:47.371 Thank you, Mr. Mazze. Everyone, we hope 01:06:47.371 --> 01:06:50.278 you found today's webinar informative. 01:06:50.278 --> 01:06:52.068 The continuing education credit code was 01:06:52.068 --> 01:06:54.181 placed in the WebExs chat throughout the 01:06:54.181 --> 01:06:56.823 presentation, and for everyone who was 01:06:56.823 --> 01:06:59.183 logged into today's webinar, you will 01:06:59.183 --> 01:07:01.771 get that code e-mailed to you within 48 01:07:01.771 --> 01:07:06.786 hours. And as Mr. Mazze said, today's 01:07:06.786 --> 01:07:09.733 webinar will be posted on CBPA.gov under 01:07:09.733 --> 01:07:11.899 the Trade outreach webinars in the 01:07:11.899 --> 01:07:13.484 coming weeks. Thank you, everyone for 01:07:13.484 --> 01:07:17.011 joining us today and this concludes 01:07:17.011 --> 01:07:20.701 today's webinar. Have a great day!SETH 01:07:20.701 --> 01:07:23.082 MAZZE: But I am still here for the 01:07:23.082 --> 01:07:28.422 chat.>>: 01:07:28.422 --> 01:07:30.520 Great, Seth, do you want me to call out a 01:07:30.520 --> 01:07:34.258 few questions from earlier?SETH 01:07:34.258 --> 01:07:35.413 MAZZE: Sandy, just the easy 01:07:35.413 --> 01:07:39.619 questions.SANDRA 01:07:39.619 --> 01:07:41.314 WALIA: So what is a difference between 01:07:41.314 --> 01:07:43.571 frameless chair and folding mattress 01:07:43.571 --> 01:07:48.218 eat? This is when you are on slide 01:07:48.218 --> 01:07:49.118 1617.SETH 01:07:49.118 --> 01:07:58.293 MAZZE: Let's see. Maybe there is a 01:07:58.293 --> 01:08:10.414 more elegant way to go back.SANDRA 01:08:10.414 --> 01:08:12.821 WALIA: I think you are around 16 or 17, 01:08:12.821 --> 01:08:15.892 frameless chair and folding mattress 01:08:15.892 --> 01:08:17.353 eat.SETH 01:08:17.353 --> 01:08:21.137 MAZZE: I think the reference may be 01:08:21.137 --> 01:08:26.134 here. This is a frameless futon. So 01:08:26.134 --> 01:08:31.513 the text of the mattress scope 01:08:31.513 --> 01:08:35.353 explicitly excludes tufted futon 01:08:35.353 --> 01:08:45.592 mattresses. This article isn't a tufted 01:08:45.592 --> 01:08:49.065 futon mattress, but it is frequently 01:08:49.065 --> 01:08:54.508 referred to as a futon. The tufted 01:08:54.508 --> 01:08:59.999 futon mattress is out of scope. This 01:08:59.999 --> 01:09:02.117 is out of scope. This is the same 01:09:02.117 --> 01:09:04.973 thing, but it is wider. And I wanted to 01:09:04.973 --> 01:09:12.344 contrast it to this which lays 01:09:12.344 --> 01:09:13.708 completely flat like a mattress. And it 01:09:13.708 --> 01:09:14.991 is my understanding that this is in 01:09:14.991 --> 01:09:19.572 scope, and these are out of scope. I 01:09:19.572 --> 01:09:22.207 need to caution everyone to take my 01:09:22.207 --> 01:09:27.529 understanding with a grain of salt. The 01:09:27.529 --> 01:09:28.926 scope determination is made by the 01:09:28.926 --> 01:09:38.206 Department of Commerce ITA International 01:09:38.206 --> 01:09:40.619 Trade Administration and if you contact 01:09:40.619 --> 01:09:44.713 me, I can show you where you can make a 01:09:44.713 --> 01:09:47.205 scope ruling, or if you just Google 01:09:47.205 --> 01:09:49.943 appropriately you can find how to make a 01:09:49.943 --> 01:09:52.910 scope request ruling of them.Next 01:09:52.910 --> 01:09:55.859 question?SANDRA 01:09:55.859 --> 01:09:57.737 WALIA: When you are on slide 24 there 01:09:57.737 --> 01:10:02.566 was a question for you to please define 01:10:02.566 --> 01:10:07.410 zero zero rate and specific rate.SETH 01:10:07.410 --> 01:10:10.096 MAZZE: This specific rate, if you were 01:10:10.096 --> 01:10:12.137 to look at the federal register notice 01:10:12.137 --> 01:10:16.135 or the message numbers, there are many, 01:10:16.135 --> 01:10:22.312 many companies that have specific rates. 01:10:22.312 --> 01:10:26.710 I don't know if it is 50 companies or 01:10:26.710 --> 01:10:29.772 more. And many of the specific rates 01:10:29.772 --> 01:10:32.753 are identical at this amount. But to 01:10:32.753 --> 01:10:36.426 know for sure, it depends on who the 01:10:36.426 --> 01:10:38.384 manufacturer is, and we would have to 01:10:38.384 --> 01:10:42.312 look at it in the Federal Register to 01:10:42.312 --> 01:10:45.089 see, or we could look at it in the 01:10:45.089 --> 01:10:53.356 equivalent online resource. I hope that 01:10:53.356 --> 01:10:56.584 answers the question.Here 01:10:56.584 --> 01:10:58.121 you can see that the countervailing duty 01:10:58.121 --> 01:11:06.580 rate is a very, very large breadth. You 01:11:06.580 --> 01:11:08.503 cannot give a rule of thumb because the 01:11:08.503 --> 01:11:10.569 specific rates are between 13% and 01:11:10.569 --> 01:11:14.899 almost 300%. Other question?SANDRA 01:11:14.899 --> 01:11:16.209 WALIA: There is a request to take a 01:11:16.209 --> 01:11:22.257 look at slide 42 and slide 43.SETH 01:11:22.257 --> 01:11:26.675 MAZZE: There is 42, a cheval mirror. I 01:11:26.675 --> 01:11:29.694 did not know what a cheval mirror is 01:11:29.694 --> 01:11:32.914 until I started this myself although I 01:11:32.914 --> 01:11:36.529 owned one. They are out of scope. They 01:11:36.529 --> 01:11:38.946 are explicitly out of scope in the 01:11:38.946 --> 01:11:39.849 description and the out of scope 01:11:39.849 --> 01:11:43.568 description says that they are typically 01:11:43.568 --> 01:11:45.003 50 inches tall and that they typically 01:11:45.003 --> 01:11:49.222 have it.43? 01:11:49.222 --> 01:12:00.317 Okay, so this scope excludes furniture 01:12:00.317 --> 01:12:02.927 parts that do not have the character of 01:12:02.927 --> 01:12:09.364 furniture. And it also excludes metal 01:12:09.364 --> 01:12:12.512 parts imported separately. And I think 01:12:12.512 --> 01:12:17.538 the example that I showed for the — I 01:12:17.538 --> 01:12:20.828 think this is a good example — that this 01:12:20.828 --> 01:12:23.739 doesn't — this part doesn't have the 01:12:23.739 --> 01:12:30.658 essential character of a bed. It also 01:12:30.658 --> 01:12:34.140 happens to be fully encased in plastic. 01:12:34.140 --> 01:12:36.560 You could take a look at the specific 01:12:36.560 --> 01:12:39.470 scope ruling to understand the logic. I 01:12:39.470 --> 01:12:45.310 really encourage people to go to use 01:12:45.310 --> 01:12:48.549 this procedure to take a look at the 01:12:48.549 --> 01:12:50.969 individual scope rulings to understand 01:12:50.969 --> 01:12:57.301 better the scopes.I 01:12:57.301 --> 01:13:00.095 found it really interesting. Next 01:13:00.095 --> 01:13:00.798 question?SANDRA 01:13:00.798 --> 01:13:02.146 WALIA: There's a question for you to 01:13:02.146 --> 01:13:11.028 pull up slide 63 please.SETH 01:13:11.028 --> 01:13:14.361 MAZZE: Okay. Do they want something 01:13:14.361 --> 01:13:16.117 particular?SANDRA 01:13:16.117 --> 01:13:17.865 WALIA: No, just for you to pull it up 01:13:17.865 --> 01:13:19.002 again.SETH 01:13:19.002 --> 01:13:22.393 MAZZE: Okay, so we can see that they 01:13:22.393 --> 01:13:25.144 are all very clearly boltless steel 01:13:25.144 --> 01:13:28.618 shelving. We can see that they don't 01:13:28.618 --> 01:13:31.048 have any fasteners. It is just a 01:13:31.048 --> 01:13:37.039 keyhole with a rivet. And we see that 01:13:37.039 --> 01:13:39.655 the deck doesn't matter. These will be 01:13:39.655 --> 01:13:46.753 rigid without the wire decking, without 01:13:46.753 --> 01:13:49.459 a particleboard decking, without the 01:13:49.459 --> 01:13:54.708 steel decking. The boltless steel shelf 01:13:54.708 --> 01:13:57.154 would still be rigid. It doesn't matter 01:13:57.154 --> 01:14:01.112 what the shelf is made of. Here are 01:14:01.112 --> 01:14:04.991 some of the other pictures. These are 01:14:04.991 --> 01:14:10.924 interesting. These were cantilever. 01:14:10.924 --> 01:14:15.732 This is out of scope as it is attached to 01:14:15.732 --> 01:14:19.396 the wall. Go ahead, another 01:14:19.396 --> 01:14:20.148 question?SANDRA 01:14:20.148 --> 01:14:22.067 WALIA: A question on slide AD one. If 01:14:22.067 --> 01:14:25.568 you can go to AD one, the question is is 01:14:25.568 --> 01:14:27.726 a single cantilever shelf or single set 01:14:27.726 --> 01:14:30.189 of cantilever shelves without supports 01:14:30.189 --> 01:14:32.566 considered in scope or out of scope for 01:14:32.566 --> 01:14:35.011 boltless steel shelving?SETH 01:14:35.011 --> 01:14:38.193 MAZZE: It is not slide AD one. Read it 01:14:38.193 --> 01:14:39.665 to me again?SANDRA 01:14:39.665 --> 01:14:41.320 WALIA: Sure. Is a single cantilever 01:14:41.320 --> 01:14:44.031 shelf or a set of cantilever shelves 01:14:44.031 --> 01:14:46.316 without vertical supports considered in 01:14:46.316 --> 01:14:48.739 scope or out of scope for boltless steel 01:14:48.739 --> 01:14:55.057 shelving?SETH 01:14:55.057 --> 01:14:57.389 MAZZE: I don't know. Let me think 01:14:57.389 --> 01:14:59.570 about it. I prefer the person to send 01:14:59.570 --> 01:15:03.538 me an email. And maybe I will encourage 01:15:03.538 --> 01:15:05.254 the person to make a ruling 01:15:05.254 --> 01:15:08.240 request.SANDRA 01:15:08.240 --> 01:15:08.583 WALIA: Okay.SETH 01:15:08.583 --> 01:15:13.334 MAZZE: There is an intersection between 01:15:13.334 --> 01:15:22.049 the furniture parts and when these 01:15:22.049 --> 01:15:25.456 pieces are imported separately. I don't 01:15:25.456 --> 01:15:28.379 believe we classified them as furniture 01:15:28.379 --> 01:15:30.846 parts. I think they are classified 01:15:30.846 --> 01:15:35.567 elsewhere. I don't recall right now. 01:15:35.567 --> 01:15:39.166 And I don't know how it impacts the 01:15:39.166 --> 01:15:39.350 antidumping or countervailing 01:15:39.350 --> 01:15:41.668 duty.SANDRA 01:15:41.668 --> 01:15:43.739 WALIA: Okay. There was a question on 01:15:43.739 --> 01:15:46.152 slide AD four. With any safes be 01:15:46.152 --> 01:15:47.805 classified here since they are 01:15:47.805 --> 01:15:49.145 specifically called out in a different 01:15:49.145 --> 01:15:49.990 chapter?SETH 01:15:49.990 --> 01:15:56.340 MAZZE: Safes we see no. These are all 01:15:56.340 --> 01:16:02.673 tool chests. The next one is slide 92. 01:16:02.673 --> 01:16:05.149 Wood gun safes or metal storage devices 01:16:05.149 --> 01:16:07.207 fall under any scope even though they 01:16:07.207 --> 01:16:11.595 are classified under 8303?SETH 01:16:11.595 --> 01:16:13.848 MAZZE: No, they are not subject to any 01:16:13.848 --> 01:16:17.501 of these cases. I don't know if there 01:16:17.501 --> 01:16:24.174 is a separate gun safe antidumping or 01:16:24.174 --> 01:16:26.643 countervailing duty work. To the best 01:16:26.643 --> 01:16:28.994 of my knowledge, no. If it is toolbox 01:16:28.994 --> 01:16:32.644 is.SANDRA 01:16:32.644 --> 01:16:34.149 WALIA: There is a question going back 01:16:34.149 --> 01:16:38.008 to your example of Chinese vanities with 01:16:38.008 --> 01:16:40.539 quartz countertops. Is an importer able 01:16:40.539 --> 01:16:41.933 to break the countertops out to a 01:16:41.933 --> 01:16:46.818 separate line item and appropriate the 01:16:46.818 --> 01:16:50.453 correct rate to each component?SETH 01:16:50.453 --> 01:16:52.353 MAZZE: That makes a lot of sense to me, 01:16:52.353 --> 01:16:57.768 but I don't know the answer. That would 01:16:57.768 --> 01:16:59.241 make a lot of sense that you would have 01:16:59.241 --> 01:17:09.717 a separate line for each antiwhaling 01:17:09.717 --> 01:17:14.020 counter duty part.SANDRA 01:17:14.020 --> 01:17:15.518 WALIA: Wooden bedroom furniture, file 01:17:15.518 --> 01:17:18.776 cabinets and desks in and out of scope? 01:17:18.776 --> 01:17:21.730 I guess they are asking if they are in 01:17:21.730 --> 01:17:24.053 and out of scope?SETH 01:17:24.053 --> 01:17:26.547 MAZZE: Out of scope — sorry — desks are 01:17:26.547 --> 01:17:30.862 not bedroom furniture and if I have a 01:17:30.862 --> 01:17:33.486 slide that says otherwise, I apologize. 01:17:33.486 --> 01:17:40.972 I will take a look. I think there may 01:17:40.972 --> 01:17:42.528 be a slide that says if your bedroom 01:17:42.528 --> 01:17:48.288 furniture had an attached desk so we get 01:17:48.288 --> 01:17:50.491 hotel furniture for example that would 01:17:50.491 --> 01:17:57.987 be a bed and a desk incorporated into 01:17:57.987 --> 01:18:00.490 the headboard. I think I wrote a ruling 01:18:00.490 --> 01:18:04.113 on one of those actually and I think we 01:18:04.113 --> 01:18:05.702 said, I think we classified it as a bed 01:18:05.702 --> 01:18:11.527 frame. But as far as the antidumping 01:18:11.527 --> 01:18:14.890 wood, if it had been Chinese, then I 01:18:14.890 --> 01:18:16.612 think we would have said it was Chinese 01:18:16.612 --> 01:18:21.411 bedroom furniture that had a desk in a 01:18:21.411 --> 01:18:23.077 desk is typically not a bedroom 01:18:23.077 --> 01:18:27.342 furniture item.SANDRA 01:18:27.342 --> 01:18:30.753 WALIA: What if a partially upholstered 01:18:30.753 --> 01:18:37.205 headboard is wall-hung?SETH 01:18:37.205 --> 01:18:40.045 MAZZE: Interesting. Headboards are 01:18:40.045 --> 01:18:43.945 still parts of bids if they are not 01:18:43.945 --> 01:18:49.774 attached to the bed frame. I think the 01:18:49.774 --> 01:18:52.328 same thing can happen with seatbacks. 01:18:52.328 --> 01:18:57.801 And a seatback can be part of a chair 01:18:57.801 --> 01:19:03.657 even if it is not attached to the legs. 01:19:03.657 --> 01:19:06.561 The question is is it subject to 01:19:06.561 --> 01:19:09.364 antidumping if it is completely 01:19:09.364 --> 01:19:13.081 upholstered? Absolutely not. If the 01:19:13.081 --> 01:19:15.580 outer surface is upholstered and it is 01:19:15.580 --> 01:19:18.677 not going to fall under the wooden 01:19:18.677 --> 01:19:24.486 Chinese bedroom furniture. If it were a 01:19:24.486 --> 01:19:25.956 wooden headboard, I would think it would 01:19:25.956 --> 01:19:33.456 fall under the Chinese wooden 01:19:33.456 --> 01:19:34.313 furniture, the upholstered wooden 01:19:34.313 --> 01:19:37.205 headboard. I think it would be subject 01:19:37.205 --> 01:19:40.049 to antidumping.SANDRA 01:19:40.049 --> 01:19:41.642 WALIA: There are a few request to pull 01:19:41.642 --> 01:19:43.942 up some slides again.Let's 01:19:43.942 --> 01:19:53.480 go back to 12 as one of them. Okay. I 01:19:53.480 --> 01:19:55.185 think they just wanted to see that one 01:19:55.185 --> 01:19:58.734 again, to pull it up. After this one 01:19:58.734 --> 01:20:09.395 would be slide 55.SETH 01:20:09.395 --> 01:20:11.611 MAZZE: I don't know why they would want 01:20:11.611 --> 01:20:15.279 to see that one. Let me see. What else 01:20:15.279 --> 01:20:26.786 is there? Okay.SANDRA 01:20:26.786 --> 01:20:31.879 WALIA: Okay, and the one more I saw, 01:20:31.879 --> 01:20:41.441 73, slide 73.SETH 01:20:41.441 --> 01:20:48.565 MAZZE: Okay, so this is — so we are 01:20:48.565 --> 01:21:00.673 talking about the boltless — slide 73 — 01:21:00.673 --> 01:21:05.294 so the boltless is here in 75. If you 01:21:05.294 --> 01:21:11.373 have a steel rack that is not boltless, 01:21:11.373 --> 01:21:12.845 let's say is bolted together, it would 01:21:12.845 --> 01:21:21.859 go here in 82. Or if you had one of 01:21:21.859 --> 01:21:28.596 these, it would go in 82. And frankly, 01:21:28.596 --> 01:21:42.247 I think this goes in 82.SANDRA 01:21:42.247 --> 01:21:45.122 WALIA: Okay. Let's just do a couple 01:21:45.122 --> 01:21:46.675 more. What is a classification number 01:21:46.675 --> 01:21:48.715 for the wall hangings shelf and set up 01:21:48.715 --> 01:21:52.914 wall hanging shelves on slide 65?SETH 01:21:52.914 --> 01:21:57.594 MAZZE: Okay, classification — so 01:21:57.594 --> 01:22:06.533 assuming that it is metal, we would say 01:22:06.533 --> 01:22:10.189 — it is not household — I don't think it 01:22:10.189 --> 01:22:19.621 is household. Off of the top of my 01:22:19.621 --> 01:22:30.759 head, my best guess would be — okay. 01:22:30.759 --> 01:22:33.846 Counters, lockers, racks, display cases, 01:22:33.846 --> 01:22:40.548 shelves. I think it is 82. No, would 01:22:40.548 --> 01:22:45.701 be 86. It is not a rack. 9403.20.86 01:22:45.701 --> 01:22:51.382 would be my best guess. Don't hold me 01:22:51.382 --> 01:22:54.148 to it. What else?SANDRA 01:22:54.148 --> 01:23:00.610 WALIA: Okay, there was a request for 01:23:00.610 --> 01:23:03.103 slide five and six. Do you want to go 01:23:03.103 --> 01:23:05.923 back to six? Five is just about where 01:23:05.923 --> 01:23:06.948 they can find the recordings in the chat 01:23:06.948 --> 01:23:10.718 box. Six, if you want to end on that 01:23:10.718 --> 01:23:13.307 one, and then we can finish up there. 01:23:13.307 --> 01:23:18.439 It is a list of the 80 CVD cases.SETH 01:23:18.439 --> 01:23:28.869 MAZZE: It is on the very last slide. 01:23:28.869 --> 01:23:32.946 And I think we can wrap up after this. I 01:23:32.946 --> 01:23:36.344 am sorry there is not a question 01:23:36.344 --> 01:23:36.844 concerning high-pressure laminate 01:23:36.844 --> 01:23:42.774 bamboo. I think that is one of the more 01:23:42.774 --> 01:23:50.946 interesting things. If it was an aside, 01:23:50.946 --> 01:23:53.344 it certainly wasn't the center of this 01:23:53.344 --> 01:23:56.329 presentation. But it is something I'm 01:23:56.329 --> 01:23:58.780 very interested in right now and very 01:23:58.780 --> 01:24:00.500 concerned about. So if there is anyone 01:24:00.500 --> 01:24:03.276 out there that is still listening that 01:24:03.276 --> 01:24:07.740 is importing bamboo furniture from China 01:24:07.740 --> 01:24:19.343 and using the 9903. 8767 number to not 01:24:19.343 --> 01:24:23.012 pay the Section 301 duties, I would 01:24:23.012 --> 01:24:28.171 certainly take a very hard look at what 01:24:28.171 --> 01:24:31.395 the substrate is, the material, and see 01:24:31.395 --> 01:24:33.766 if there is actually a high-pressure 01:24:33.766 --> 01:24:38.467 laminate on top of the bamboo substrate. 01:24:38.467 --> 01:24:41.075 And if it does not have HPL laminate 01:24:41.075 --> 01:24:45.749 on top, I would be getting ready to make 01:24:45.749 --> 01:24:53.339 prior disclosures.Okay, 01:24:53.339 --> 01:24:54.216 are there other questions that are out 01:24:54.216 --> 01:24:57.741 there, Sandy?SANDRA 01:24:57.741 --> 01:24:59.283 WALIA: There are a few more, but we 01:24:59.283 --> 01:25:01.460 don't have time to get to them.SETH 01:25:01.460 --> 01:25:03.818 MAZZE: Okay. Then I am all right. 01:25:03.818 --> 01:25:06.123 This has been interesting for me. It has 01:25:06.123 --> 01:25:08.112 been a learning process and I have 01:25:08.112 --> 01:25:12.573 enjoyed it. I thank you. I think the 01:25:12.573 --> 01:25:16.315 whole technical behind the scenes folks. 01:25:16.315 --> 01:25:18.853 I plead for mercy from the transcriber. 01:25:18.853 --> 01:25:21.534 I apologize for speaking quickly. And 01:25:21.534 --> 01:25:23.506 most of all I think the participants who 01:25:23.506 --> 01:25:25.922 took their time to listen to this and 01:25:25.922 --> 01:25:29.383 hope that it was helpful to them. And I 01:25:29.383 --> 01:25:41.257 encourage people to please feel free to 01:25:41.257 --> 01:25:43.241 reach out to me at my email or at my 01:25:43.241 --> 01:25:44.537 phone number. Email is easiest. And I 01:25:44.537 --> 01:25:45.882 would be happy to go down a rabbit hole 01:25:45.882 --> 01:25:48.154 or take a look and see what I can about 01:25:48.154 --> 01:25:52.691 this.SANDRA 01:25:52.691 --> 01:25:53.584 WALIA: 01:25:53.584 --> 01:25:56.073 >>: Great. Thank you, Mr. 01:25:56.073 --> 01:25:59.151 Mazze.CALENTHIA 01:25:59.151 --> 01:26:01.411 BANKS: Today's webinar will be posted 01:26:01.411 --> 01:26:06.957 on CBP.gov under the Trade out reach 01:26:06.957 --> 01:26:09.610 webinars in the coming weeks. We have 01:26:09.610 --> 01:26:10.819 placed the code in the chat and it will 01:26:10.819 --> 01:26:13.397 be e-mailed out within 48 hours. Thank 01:26:13.397 --> 01:26:15.734 you for joining us today and this 01:26:15.734 --> 01:26:16.937 concludes today's webinar. Have a great 01:26:16.937 --> 01:26:22.987 day everyone.SETH 01:26:22.987 --> 01:26:24.940 MAZZE: Thank you, everyone. I 01:26:24.940 --> 01:26:29.134 appreciate it. Goodbye.CAPTIONER: 01:26:29.509 --> 01:26:29.509 PM (ET)