WEBVTT VTT

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>> CHRISSI GUTH: Good afternoon. I
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am Chrissi Guth with CBP office with
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trade relations and today's webinar is
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classification of bamboo Chapter 44,
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HTSUS.
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The webinar is a part of the NCSD's
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2023 webinar series. Please be mindful
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that you will be on mute during the
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presentation. Therefore, we ask that
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you submit any questions you have in the
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chat feature. Now I like to pass it
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over to national import specialist,
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Laurel Duvall.
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>> LAUREL DUVALL: Hi, everybody.
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Welcome. Hopefully you're all settled
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now. My name is Laurel Duvall. I'm the
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national import specialist for wood
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products. If that doesn't sound
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familiar to you, you might know me by my
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former name, Wood Princess. That's what
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it shows on my business card and today
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we are here to talk about bamboo
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classification. So if you have worked
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with classifying bamboo products, you
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know they can be a little tricky. So,
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hopefully, we'll get you little bit of
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clarification today. And if nothing
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else, you get my email address so you
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can ask me some time later. As Chrissy
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noted, if you have questions today
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during our presentation, please put them
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in the chat and we'll address them at
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the end. The presentation is about an
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hour. And you'll probably notice that
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there are people from CBP and from the
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trade here on our presentation today.
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And so if you happen to be in the
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bamboo industry, and I'm telling you
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things that you already completely know,
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sorry about that. Please be patient
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with me as I'm sharing the information
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with a lot of different audiences. So
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hang in there.
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And let's get going. I'm going to
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turn off my camera so you don't get
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distracted by my face. [Laughter]
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because it can be distracting that way.
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But let's get going on bamboo. Okay.
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Sorry. New computer sys.
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Here we go. All right. So here is
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my contact information. Please contact
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me by email. That's the best way to get
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a hold of me. I'm not necessarily
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always in the office and I like to get
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you an answer quickly. I do answer
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everything. I'm kind of weird that way.
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So if you have a question, please let
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me know. Please do not contact me and
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ask me what the classification of your
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product is. I don't give classification
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advice. We only give binding
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determinations here. So I can talk to
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you about what things mean, but I'm not
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going to classify your products for you.
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And also if you're in CBP, please don't
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instant message me. I can't always drop
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what I'm doing and so the best way to
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get hold of me is by email.
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Okay. So as always, quick
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disclaimer. This webinar is for general
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information purposes only. And
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listening to it does not constitute
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reasonable care. So if some import
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specialist sends you a rate advance and
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your answer is, well, Laurel said blah,
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blah in a webinar, that's not reason
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enough. The best thing to do is to get
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yourself a binding classification
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ruling. And they are easy to get. You
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can request them electronically now. E
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ruling start CBP.gov. They are free.
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So you don't have to pay a sent for
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them. Assuming you provide us with all
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the information that we need, your
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ruling will be issued within 30 days
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from the date of receipt. So you won't
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be sitting around waiting for them
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either.
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The important thing to note is
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national comomed tea specialist division
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can issue rulings on prospective
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transactions. Things we haven't
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imported yet, we can't rule on current
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or past transactions. So if you get
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that rate of advance and you don't agree
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with the specialist, you can't come to
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us to get a ruling, because it's a
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current transaction.
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Also it's important to note that we
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cannot rule on matters of antidumping or
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Countervailing duties. That is
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jurisdiction of commerce. And we get
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asked all the time, what's the
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classification, am I good to
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antidumping? Unfortunately, we can't
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tell you. If you want the formal
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ruling, you have to go to development of
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commerce. So let's talk about bamboo.
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Of course, you hear about bamboo a
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lot in the market and in the media, and
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you know, it's a green material. And
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all of that. But bamboo is kind of
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unique and cool. It's the world's
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fastest producer of biomass. It can
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literally grow up to a meter a day. If
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you're not metric inclined, that means
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over a yard a day. Manning sitting in
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your kitchen and watching a tree grow a
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yard in one day. That would be crazy,
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right? But that's the great thing about
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bamboo is that it's superfast growing.
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It's a grass. It's not a tree. And as
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material, it's highly durable and
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versatile. And when it's used in place
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of wood, it reduces pressure on hardwood
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forest. So it's a unique and great
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material to be working with from my
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perspective.
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I recommend you don't underestimate
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the possibilities of bamboo. Long gone
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are the days when bamboo was used
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forecast away huts on desert aisles.
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You know, this building you see in the
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center picture is a welcome center for
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resort in Vietnam. It's a highly
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durable material that's, you know, very
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workable. So it can be made into these
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intricate buildings. And it's totally
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stable as standard construction
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buildings may be. So it's a really
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interesting material.
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And if you happen to have aired on
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to Hong Kong or another Asian city, you
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might see ultra modern skyscraper with
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primitive bamboo scaffolding. It's a
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really great material for this. It's
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cheap. It's strong. It's lightweight.
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And it actually has benefits over the
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kind of steel scaffolding that we're
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accustomed to in the U.S. And it's just
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interesting to see in action.
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But today, we're going to be talking
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about bamboo classification,
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specifically in Chapter 44. And the
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kinds of products we're going to be
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seeing there are things like building
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materials, molding, flooring. We're
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going to talk a lot about flooring here
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today. And just, you know, materials
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that typically go into construction of
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buildings and other structures. So
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let's get with it.
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Okay. So bamboo is grass. Chapter
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44 is where wood is classified. So why
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is grass classified with wood? And the
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reason is note 6 to Chapter 44. And
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note 6 specifically tell us that any
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reference to the word "wood" in Chapter
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44 in any heading of Chapter 44 applies
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also to bamboo and other materials of
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Woody nature.
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So bamboo is a material of Woody
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nature. If you look at a piece of
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bamboo flooring, for all intents and
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purposes, it's pretty much the same as
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wood. So that is why, you know, all of
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these products go directly to Chapter 44
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for classification and not to some place
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where other vegetable materials are
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classified. Now, look at the structure
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of bamboo and see what you notice about
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it.
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One, it's round. That's different.
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It's hollow. The wall of bamboo has a
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relatively thin cross-section. So in
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this case, probably 5 to 6-millimeter on
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the pole to the left. Generally
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speaking, compared to trees, the
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diameter is much smaller. The interior
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of it is broken into, like, large open
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cells with you can see these kinds of
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horizontal breaks on the inside of the
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bamboo poles. And all of these things
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impact how bamboo is used in
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manufacturing.
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So bamboo is hollow and has a narrow
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cross-section. So what does that mean
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for its use as a construction material?
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Well, bamboo isn't like wood. It's not
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like a tree. It's not solid. So it's
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not like with a tree trunk, you can't
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cut a big slab of it, right? It's not
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solid. It's hollow. So all you have to
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work with is that wall, right? And it's
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only so thick. So how do you get that
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material and make larger things out of
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it? Right? Because there's not a lot
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of material, and it's what is there is
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limited in size. So if you imagine the
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wall being broken down into several
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pieces, you know, around the
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circumference of it, you get pieces of
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workable material.
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And they tend to look like these
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strips on the left. Okay, so you can
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see these strips are 5, 6, 7-millimeter
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thick, and maybe 1 to 2-centimeter in
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width. But you're not going to get
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anything much bigger out of bamboo. So
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bamboo products can't be made of solid
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uninterrupted bamboo, or for the most
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part, every once in a while that can be
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made of solid uninterrupted bamboo, but
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for the most part, even small items have
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to be made of multiple pieces of bamboo
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bonded together to form a large hole.
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So you see these two moldings here. T
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molding and a quarter round. And this
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quart rawnd is an one niche square. And
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you can see the semis of multiple pieces
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of bamboo glued together to form a
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whole. So small molding that's not even
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an inch square, it still requires that
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pieces of Bambi glued together to form a
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larger piece of material to make things
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out of.
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And same thing with this T molding.
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You can see these seems all the way
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across. It shows that the molding is
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made of several strips glued
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side-by-side.
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Okay, and just a few things about
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features of bamboo. Nodes. Do you see
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these circular rings around the bamboo
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poles that, you know, are just what you
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imagine when you think of bamboo, these
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circular rings. And they're called
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nodes. And internal to the bamboo,
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they're actually these diaphragms that
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act as mechanical support to the inside
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of the pole. So this, you know, shows
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that the pole is hollow. But it does
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have these breaks in it. And
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interestingly, they're recognizable in
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certain products. So I'll show you how
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to recognize them. So here is the top
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of the surface of a horizontal bamboo
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flooring panel. And you can see these
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little areas where it looks like there's
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kind of a crunch of the little lines and
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dots, and you know, looks like two
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pieces kind of colliding together.
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Those are the nodes. So those are where
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the horizontal dividing diaphragms from
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inside the pole, those are where they
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show up in the bamboo product. So if
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you see something like this, if I give
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you a piece of a -- you know, if I give
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you a piece of flooring panel and you
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see those nodes, it's a dead give away
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that it's a product made of bamboo. So
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it's useful.
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Okay, also, carbonized. If you're
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looking at entry documents for bamboo
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products, you're often going to see the
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word "carbonized" or "natural" on it.
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It's heat treating, steaming, or smoking
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the bamboo to give it a darker color.
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Carbonizing, you can see on the left,
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this is what color natural bamboo
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usually is, this light blonde color and
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carbonized is a darker color. It's
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important to know car Bobbizeing doesn't
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impact classification. But if you see
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it on a document, you know what it's
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talking about.
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The thing that does govern
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classification is construction. First
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and foremost with bamboo products, the
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construction is going to be the most
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important thing you're going to have to
00:14:35.336 --> 00:14:37.984
concern yourself with. So all three of
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these products are classified by their
00:14:40.360 --> 00:14:42.850
construction. You can see this top one
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on the left has these strips glued
00:14:45.689 --> 00:14:48.024
side-by-side. This one in the center is
00:14:48.024 --> 00:14:50.486
actually strands all agglomerated
00:14:50.486 --> 00:14:53.229
together so they're pushed, pressed
00:14:53.229 --> 00:14:56.804
together in a block. And this one on
00:14:56.804 --> 00:15:00.243
the right is actually a plywood
00:15:00.243 --> 00:15:01.338
construction so, these are all going to
00:15:01.338 --> 00:15:05.526
be treated differently.
00:15:05.526 --> 00:15:07.042
The three most common constructions
00:15:07.042 --> 00:15:09.165
you're going to see, you know, because
00:15:09.165 --> 00:15:11.115
chances are most of what you're going to
00:15:11.115 --> 00:15:13.771
see is going to be flooring. They're
00:15:13.771 --> 00:15:17.810
horizontal, vertical, and strand. Okay,
00:15:17.810 --> 00:15:20.189
so this is what horizontal looks like.
00:15:20.189 --> 00:15:24.031
Horizontal bamboo flooring is almost
00:15:24.031 --> 00:15:25.951
always 3 layers. And the strips are
00:15:25.951 --> 00:15:28.195
glued together side-by-side along their
00:15:28.195 --> 00:15:31.501
narrow edges. So it's going to form
00:15:31.501 --> 00:15:33.552
this up in the air. And they're usually
00:15:33.552 --> 00:15:36.793
made of 3 layers. Okay? Now, if you
00:15:36.793 --> 00:15:41.537
look at the profile of each individual
00:15:41.537 --> 00:15:44.965
strip, you'll see where at least I
00:15:44.965 --> 00:15:47.365
believe the word "horizontal" comes
00:15:47.365 --> 00:15:50.691
from, because the strips are oriented in
00:15:50.691 --> 00:15:55.559
a horizontal direction.
00:15:55.559 --> 00:15:59.804
Vertical is where the strips are
00:15:59.804 --> 00:16:02.315
stood up on the narrow sides and glued
00:16:02.315 --> 00:16:05.950
together wide facessed to wide faced.
00:16:05.950 --> 00:16:07.525
And these are oriented in a single
00:16:07.525 --> 00:16:09.963
layer. And if you look at the profile
00:16:09.963 --> 00:16:13.078
of a single strip, you can see that it's
00:16:13.078 --> 00:16:15.645
oriented in a vertical manner relative
00:16:15.645 --> 00:16:21.162
to the horizontal. So you can see the
00:16:21.162 --> 00:16:22.729
difference. And there's this strand.
00:16:22.729 --> 00:16:27.074
And I've got this cookie, you know,
00:16:27.074 --> 00:16:29.538
squiggly that I've drawn here. And
00:16:29.538 --> 00:16:31.851
strand is almost what it sounds like
00:16:31.851 --> 00:16:43.595
where strands or like shreds are bamboo
00:16:43.595 --> 00:16:46.302
are pressed together into a block. It's
00:16:46.302 --> 00:16:49.605
made these bamboo strands. So those are
00:16:49.605 --> 00:16:51.307
the 3 that you're going to see the most
00:16:51.307 --> 00:16:54.915
often.
00:16:54.915 --> 00:16:57.577
Okay. So the important thing to
00:16:57.577 --> 00:17:01.340
know about bamboo is that because all of
00:17:01.340 --> 00:17:05.219
these items have to be made of multiple
00:17:05.219 --> 00:17:09.351
pieces of bamboo or multiple strands all
00:17:09.351 --> 00:17:14.473
put together, they're not considered
00:17:14.473 --> 00:17:16.691
solid wood for classification purposes.
00:17:16.691 --> 00:17:18.895
It's really important. You might see
00:17:18.895 --> 00:17:22.604
something on an invoice saying solid
00:17:22.604 --> 00:17:25.055
bamboo flooring. It's not solid. It's
00:17:25.055 --> 00:17:26.531
multiple pieces of wood, either
00:17:26.531 --> 00:17:30.970
laminated or bonded together, or
00:17:30.970 --> 00:17:34.177
agglomerated strands. So none of these
00:17:34.177 --> 00:17:36.316
products here that you see here, you can
00:17:36.316 --> 00:17:38.671
see the top one has a horizontal
00:17:38.671 --> 00:17:40.428
orientation, the middle one has a
00:17:40.428 --> 00:17:42.675
vertical, and the bottom has a strand.
00:17:42.675 --> 00:17:45.477
None of these are considered solid wood
00:17:45.477 --> 00:17:49.174
for classification purposes.
00:17:49.174 --> 00:17:51.164
Okay, I have couple of funny slides
00:17:51.164 --> 00:17:53.551
in the middle of this, you know, to give
00:17:53.551 --> 00:17:56.234
you a moment's break. And I saw this,
00:17:56.234 --> 00:17:58.435
and it was just about the funniest thing
00:17:58.435 --> 00:18:00.906
I've ever seen. You know how people go
00:18:00.906 --> 00:18:06.278
out and do yoga on paddle boards? Well,
00:18:06.278 --> 00:18:10.010
why do that when you can challenge
00:18:10.010 --> 00:18:12.032
yourself more by going on the water and
00:18:12.032 --> 00:18:16.374
balancing on a bamboo pole. [Laughter]
00:18:16.374 --> 00:18:18.348
they're lying there in the splits.
00:18:18.348 --> 00:18:22.700
[Laughter] I'm sorry. [Laughter] it
00:18:22.700 --> 00:18:25.258
still makes me laugh every time I look
00:18:25.258 --> 00:18:31.977
at it. I give these people creativity.
00:18:31.977 --> 00:18:33.881
Paddle boards are so lame. These are so
00:18:33.881 --> 00:18:36.848
much better. Onward. Okay.
00:18:36.848 --> 00:18:39.380
So where are bamboo products
00:18:39.380 --> 00:18:42.512
classified? Classification, first and
00:18:42.512 --> 00:18:45.060
foremost, like I said depends on the
00:18:45.060 --> 00:18:46.620
construction. And secondly, it depends
00:18:46.620 --> 00:18:48.789
on the identity of the product. Okay?
00:18:48.789 --> 00:18:50.682
So you're going to be asking yourself a
00:18:50.682 --> 00:18:53.134
lot of questions. Is the product
00:18:53.134 --> 00:18:55.595
flooring? Is it plywood? Is it a
00:18:55.595 --> 00:18:58.444
molding? Is it multilayer? How thick
00:18:58.444 --> 00:19:03.114
is the face ply? What's the use of the
00:19:03.114 --> 00:19:04.816
product? Is it used in the construction
00:19:04.816 --> 00:19:07.002
of the building? All these things
00:19:07.002 --> 00:19:11.444
impact classification. So just so
00:19:11.444 --> 00:19:14.874
you're aware, it's not usually super
00:19:14.874 --> 00:19:16.076
straightforward where it guess. So
00:19:16.076 --> 00:19:18.209
let's talk about the classifications
00:19:18.209 --> 00:19:19.845
themselves.
00:19:19.845 --> 00:19:23.679
Veneers of heading 4408. You're
00:19:23.679 --> 00:19:25.589
probably not going to be classifying
00:19:25.589 --> 00:19:27.251
many of these, but it's ponder to
00:19:27.251 --> 00:19:31.477
understand the veneers of bamboo. So
00:19:31.477 --> 00:19:34.826
veneer by tariff definition is a sheet
00:19:34.826 --> 00:19:39.111
of wood measuring 6-millimeter or less
00:19:39.111 --> 00:19:41.705
in thickness. So this picture on the
00:19:41.705 --> 00:19:44.286
left, this top one looks like what you
00:19:44.286 --> 00:19:47.056
expect of a typical veneer. It's super
00:19:47.056 --> 00:19:51.152
thin. But bottom picture is also a
00:19:51.152 --> 00:19:53.527
veneer. Okay? Even though it looks
00:19:53.527 --> 00:19:56.369
like a thin board instead of a thin
00:19:56.369 --> 00:20:01.350
sheet. As long as it is a sheet of some
00:20:01.350 --> 00:20:06.014
variety, and it is at least no more than
00:20:06.014 --> 00:20:08.225
6-millimeter in thickness, then it is
00:20:08.225 --> 00:20:10.348
considered a veneer. And you're going
00:20:10.348 --> 00:20:15.007
to see these veneers placed on top of
00:20:15.007 --> 00:20:17.300
different substrates, like with
00:20:17.300 --> 00:20:19.613
engineered flooring.
00:20:19.613 --> 00:20:21.790
So the important thing to know about
00:20:21.790 --> 00:20:24.169
veneers is that the explanatory note
00:20:24.169 --> 00:20:26.498
tell us that the veneers can be made in
00:20:26.498 --> 00:20:31.055
two ways. And if you deal with plywood,
00:20:31.055 --> 00:20:39.835
and regular wood veneer products, you
00:20:39.835 --> 00:20:42.408
know veneers are period from the log.
00:20:42.408 --> 00:20:43.945
They take a log and put it on the
00:20:43.945 --> 00:20:46.600
spinned dull and spin the log and the
00:20:46.600 --> 00:20:50.331
veneer peels off of it like a role of
00:20:50.331 --> 00:20:53.221
paper towels. But the explanatory notes
00:20:53.221 --> 00:20:55.795
also tell you also if the V can be slice
00:20:55.795 --> 00:20:58.642
dollars from a block of pieces that are
00:20:58.642 --> 00:21:03.046
laminated together or wood that's
00:21:03.046 --> 00:21:05.710
agglomerated together, if you take
00:21:05.710 --> 00:21:07.593
bamboo strips and you glue them
00:21:07.593 --> 00:21:09.938
altogether and make a great big block,
00:21:09.938 --> 00:21:13.126
and you slice off 4-millimeter thick
00:21:13.126 --> 00:21:15.822
sheets off of this block, those are
00:21:15.822 --> 00:21:20.230
considered veneers too. So even though
00:21:20.230 --> 00:21:21.772
it's a manufactured product, and it's
00:21:21.772 --> 00:21:26.108
not just peeled directly from a log,
00:21:26.108 --> 00:21:28.556
it's still considered a veneer. But 6
00:21:28.556 --> 00:21:34.145
millimeters is that dividing line.
00:21:34.145 --> 00:21:38.752
Okay. 4409. This is a really
00:21:38.752 --> 00:21:42.760
interesting topic here, to me. I'll say
00:21:42.760 --> 00:21:44.427
everything here is interesting to me. I
00:21:44.427 --> 00:21:47.853
can't speak for anybody else. Wood
00:21:47.853 --> 00:21:51.535
continuously shaped is provided for
00:21:51.535 --> 00:21:55.502
4409. So wood continuously shaped along
00:21:55.502 --> 00:21:59.965
any of the edges and faces. And this is
00:21:59.965 --> 00:22:02.950
typically moldings go and solid wood
00:22:02.950 --> 00:22:05.750
flooring goes. And bamboo products are
00:22:05.750 --> 00:22:07.679
often continuously shaped. And that
00:22:07.679 --> 00:22:10.698
means basically that it has a continuous
00:22:10.698 --> 00:22:12.998
profile throughout its length. So you
00:22:12.998 --> 00:22:16.110
can see the 5 products here are all
00:22:16.110 --> 00:22:17.907
bamboos. And they're all continuously
00:22:17.907 --> 00:22:20.327
shaped. They have a single profile and
00:22:20.327 --> 00:22:22.253
the profile extends throughout the
00:22:22.253 --> 00:22:24.478
length of the board.
00:22:24.478 --> 00:22:28.933
But are these products down here
00:22:28.933 --> 00:22:32.069
classifiable in heading 4409? It's
00:22:32.069 --> 00:22:35.006
continuously shaped, but does it go on
00:22:35.006 --> 00:22:39.814
4409? And the answer is no. Now,
00:22:39.814 --> 00:22:42.697
4409.21 is a subheading in 4409 that
00:22:42.697 --> 00:22:45.152
provides for continuously shaped board
00:22:45.152 --> 00:22:47.943
of bamboo, right? So it kind of sounds
00:22:47.943 --> 00:22:50.414
like your modulings go there, right?
00:22:50.414 --> 00:22:53.385
But they don't. And why is it that
00:22:53.385 --> 00:22:57.588
almost nothing else classifiable here?
00:22:57.588 --> 00:23:02.387
The reason why is because 44089 provides
00:23:02.387 --> 00:23:05.286
only for are continuous solid wood.
00:23:05.286 --> 00:23:08.624
Okay? It can be joined at the ends to
00:23:08.624 --> 00:23:11.137
make it longer. You can see the end of
00:23:11.137 --> 00:23:13.946
the language, whether or not plain
00:23:13.946 --> 00:23:16.188
sanded or end jointed. It can be end
00:23:16.188 --> 00:23:21.572
jointed to make the molding longer. But
00:23:21.572 --> 00:23:23.713
the language of the heading does not
00:23:23.713 --> 00:23:31.083
provide for edge gluing, pieces
00:23:31.083 --> 00:23:32.508
side-by-side. If you look at the
00:23:32.508 --> 00:23:34.680
explanatory notes, it also specifically
00:23:34.680 --> 00:23:38.817
says that goods of 4409 can't be
00:23:38.817 --> 00:23:40.871
superimposed either. So you can't have
00:23:40.871 --> 00:23:43.798
wood glued on top of each other, right?
00:23:43.798 --> 00:23:46.249
And driving the point home even more,
00:23:46.249 --> 00:23:49.656
the explanatory notes tell us 4409 are
00:23:49.656 --> 00:23:52.111
constructed of timber and timber is
00:23:52.111 --> 00:23:54.434
solid wood. Once you start tbleug
00:23:54.434 --> 00:23:56.672
things together, you've got a product
00:23:56.672 --> 00:24:00.125
that's engineered. And it no longer
00:24:00.125 --> 00:24:03.094
fits into the confines of heading 4409.
00:24:03.094 --> 00:24:07.047
So all of these products are all
00:24:07.047 --> 00:24:08.846
constructed of bamboo. And you can see
00:24:08.846 --> 00:24:11.408
they're made of multiple strips glued
00:24:11.408 --> 00:24:14.151
together, side-by-side, up and down, and
00:24:14.151 --> 00:24:16.326
none of these products is going to be
00:24:16.326 --> 00:24:19.156
classified in 4409, because none of them
00:24:19.156 --> 00:24:21.122
are solid wood. They're all made of
00:24:21.122 --> 00:24:22.959
multiple pieces joined together to form
00:24:22.959 --> 00:24:26.356
a larger whole.
00:24:26.356 --> 00:24:29.739
The only product I have ever seen
00:24:29.739 --> 00:24:33.861
that was correctly classified in 4409.21
00:24:33.861 --> 00:24:37.840
was 3-millimeter diameter of bamboo
00:24:37.840 --> 00:24:40.333
rods. And chances are you're not going
00:24:40.333 --> 00:24:44.539
to see these. You know, these aren't
00:24:44.539 --> 00:24:48.121
the greatest -- they're not the largest
00:24:48.121 --> 00:24:50.136
bamboo import into the United States by
00:24:50.136 --> 00:24:53.276
any stretch. But the thing is, you
00:24:53.276 --> 00:24:57.892
remember that bamboo shape, and it's
00:24:57.892 --> 00:25:00.135
hollow, and it's got the wall that's
00:25:00.135 --> 00:25:02.738
only so thick and there's only so much
00:25:02.738 --> 00:25:07.325
you can get out of that tiny cross
00:25:07.325 --> 00:25:10.337
section to make a solid product. And if
00:25:10.337 --> 00:25:13.434
the thickness of the wall of the bamboo
00:25:13.434 --> 00:25:16.319
is 6 millimeters, then getting a
00:25:16.319 --> 00:25:19.437
continuously shaped round profile that's
00:25:19.437 --> 00:25:22.113
3 millimeters in diameter is possible.
00:25:22.113 --> 00:25:24.276
So this is literally the only product
00:25:24.276 --> 00:25:27.206
I've ever seen that's correctly
00:25:27.206 --> 00:25:29.188
classified there.
00:25:29.188 --> 00:25:31.813
So if you have flooring, if you have
00:25:31.813 --> 00:25:36.065
moldings, if you have construction
00:25:36.065 --> 00:25:39.653
material panels, none of these. None,
00:25:39.653 --> 00:25:42.770
none, none are going to be classified in
00:25:42.770 --> 00:25:45.771
heading 4409. Regardless of the fact
00:25:45.771 --> 00:25:47.255
they're continuously shaped, it doesn't
00:25:47.255 --> 00:25:48.469
matter, that part of the language is
00:25:48.469 --> 00:25:51.702
only part of what is a requirement for
00:25:51.702 --> 00:25:53.740
4409. But if they're made of bamboo and
00:25:53.740 --> 00:25:56.161
multiple pieces that are put together to
00:25:56.161 --> 00:25:58.270
form a larger whole, then they're not
00:25:58.270 --> 00:26:00.790
going to go in 4409.
00:26:00.790 --> 00:26:02.855
So where are they going to go?
00:26:02.855 --> 00:26:07.708
Probably in 4412 or 4418. Sometimes
00:26:07.708 --> 00:26:09.362
4421, depending on the product, but for
00:26:09.362 --> 00:26:13.121
the most part, 4412 and 4418. 4412
00:26:13.121 --> 00:26:16.591
provides for plywood veneer panels in
00:26:16.591 --> 00:26:19.769
similar laminated wood and 4418 for
00:26:19.769 --> 00:26:23.259
builders joinery of carpentry of wood.
00:26:23.259 --> 00:26:24.958
The important thing that you have to
00:26:24.958 --> 00:26:30.006
know in classifying these two headings,
00:26:30.006 --> 00:26:31.486
first you have to determine if the
00:26:31.486 --> 00:26:35.588
product is classifiable in 4412? Is it
00:26:35.588 --> 00:26:40.100
plywood or veneered panel or similar
00:26:40.100 --> 00:26:43.020
laminated wood? If it's disqualified by
00:26:43.020 --> 00:26:45.567
a note from the chapter, then you move
00:26:45.567 --> 00:26:49.981
on to 4418. But you have to disqualify
00:26:49.981 --> 00:26:51.626
4412 first.
00:26:51.626 --> 00:26:56.452
So why 4418? Why builders' joinery?
00:26:56.452 --> 00:26:58.903
That might not seem totally clear.
00:26:58.903 --> 00:27:02.274
What we see for bamboo is flooring and
00:27:02.274 --> 00:27:05.675
moldings. And flooring and moldings are
00:27:05.675 --> 00:27:07.481
recognizable articles used in the
00:27:07.481 --> 00:27:09.266
construction of the building. If you
00:27:09.266 --> 00:27:11.406
hand me a piece of bamboo flooring or
00:27:11.406 --> 00:27:13.338
hand me a t molding or something like
00:27:13.338 --> 00:27:15.572
that, I know they go into a building,
00:27:15.572 --> 00:27:16.113
right?
00:27:16.113 --> 00:27:21.282
Well, the language builders' joinery
00:27:21.282 --> 00:27:24.101
is defined in the explanatory note in
00:27:24.101 --> 00:27:26.318
the harmonized system in the recognized
00:27:26.318 --> 00:27:28.991
notes of a construction building. So
00:27:28.991 --> 00:27:32.815
4418 is a proper place to put flooring
00:27:32.815 --> 00:27:35.360
and moldings and things that are
00:27:35.360 --> 00:27:37.448
incorporated into a building that aren't
00:27:37.448 --> 00:27:40.256
classified some place else. So 4418 is
00:27:40.256 --> 00:27:41.909
good.
00:27:41.909 --> 00:27:44.838
Okay. So let's talk about what 4412
00:27:44.838 --> 00:27:48.649
means. Plywood, veneered panels, and
00:27:48.649 --> 00:27:52.205
similar laminated wood. Is very, very
00:27:52.205 --> 00:27:54.549
important that you understand that these
00:27:54.549 --> 00:27:57.584
terms, when we're talking about the
00:27:57.584 --> 00:28:00.034
tariff schedule, these terms are
00:28:00.034 --> 00:28:03.168
referencing constructions. They're not
00:28:03.168 --> 00:28:07.568
referencing specific products. Okay?
00:28:07.568 --> 00:28:10.378
So if you go to Home Depot, and you say
00:28:10.378 --> 00:28:12.752
I like to buy some plywood, and they
00:28:12.752 --> 00:28:15.759
send you over to the aisle with 4x8
00:28:15.759 --> 00:28:19.501
sheets of Burch plywood, that's not what
00:28:19.501 --> 00:28:23.091
this term means. This term is talking
00:28:23.091 --> 00:28:26.975
about a panel, any kind of panel that
00:28:26.975 --> 00:28:30.816
has at least 3 layers glued together
00:28:30.816 --> 00:28:33.976
with the grain of each layer oriented at
00:28:33.976 --> 00:28:36.401
an angle to the adjacent layers. So,
00:28:36.401 --> 00:28:38.692
like, one layer is lengthwise grain.
00:28:38.692 --> 00:28:40.833
One layer is cross-wise grain. The next
00:28:40.833 --> 00:28:43.241
layer is lengthwise grain, and so on.
00:28:43.241 --> 00:28:45.116
Right?
00:28:45.116 --> 00:28:49.675
So that description does, in fact,
00:28:49.675 --> 00:28:53.142
describe your Burch plywood panel. But
00:28:53.142 --> 00:28:56.317
thing is it also describes engineered
00:28:56.317 --> 00:28:58.369
flooring so, if you're familiar with
00:28:58.369 --> 00:29:00.842
engineered flooring, it's not a tariff
00:29:00.842 --> 00:29:03.391
term. But it's basically, you know,
00:29:03.391 --> 00:29:05.692
flooring of a multilayer plywood
00:29:05.692 --> 00:29:11.233
construction. So that word plywood, you
00:29:11.233 --> 00:29:13.356
know, that you can see there's a
00:29:13.356 --> 00:29:21.300
subheading there, 4412.10 pent 500.
00:29:21.300 --> 00:29:23.076
Flooring is going to go into the
00:29:23.076 --> 00:29:25.431
classification. Even the plywood you
00:29:25.431 --> 00:29:28.025
buy at Home Depot, that's not what that
00:29:28.025 --> 00:29:30.541
term means. So second is veneered
00:29:30.541 --> 00:29:35.004
panels. And that means veneer of fixed
00:29:35.004 --> 00:29:37.475
to a base. And the explanatory notes
00:29:37.475 --> 00:29:39.865
tell us that's usually inferior wood.
00:29:39.865 --> 00:29:42.237
But it can be other materials too. As
00:29:42.237 --> 00:29:46.880
long as the veneer itself gives the
00:29:46.880 --> 00:29:48.516
essential character, so if you have a
00:29:48.516 --> 00:29:51.619
wood veneer, affixed to a stone plastic
00:29:51.619 --> 00:29:53.886
composite base, that's a veneer panel,
00:29:53.886 --> 00:29:56.198
because the wood veneer on top is what
00:29:56.198 --> 00:30:00.304
gives the product its consumer appeal.
00:30:00.304 --> 00:30:02.439
When it's installed, it looks like you
00:30:02.439 --> 00:30:04.074
have a wood floor, right?
00:30:04.074 --> 00:30:10.558
The stone plastic composite base
00:30:10.558 --> 00:30:13.479
enhances the fact it's a wood. And it
00:30:13.479 --> 00:30:17.981
can also be high-density fiber board.
00:30:17.981 --> 00:30:22.199
It can be plastic. The base importantly
00:30:22.199 --> 00:30:25.353
can be wood where the grain runs
00:30:25.353 --> 00:30:28.419
parallel to the face ply. Because
00:30:28.419 --> 00:30:30.674
remember, plywood, at least 3 layers
00:30:30.674 --> 00:30:33.492
where the grains usually alternate
00:30:33.492 --> 00:30:35.365
directions, right? But what if all the
00:30:35.365 --> 00:30:37.410
grains run in the same direction? It's
00:30:37.410 --> 00:30:40.894
not plywood. Right? Then it's a veneer
00:30:40.894 --> 00:30:42.578
panel. Okay?
00:30:42.578 --> 00:30:46.592
So a veneer affixed to a base and
00:30:46.592 --> 00:30:48.387
similarly for laminated W50D, we won't
00:30:48.387 --> 00:30:50.442
talk too much about that, but at least
00:30:50.442 --> 00:30:55.177
it's 2 outer veneers and CORE lumber.
00:30:55.177 --> 00:31:03.010
So talking about blook board or lumber
00:31:03.010 --> 00:31:06.033
CORE panels. And laminated wood is
00:31:06.033 --> 00:31:07.613
almost a plywood construction. But
00:31:07.613 --> 00:31:10.567
those are what those 3 terms means. So
00:31:10.567 --> 00:31:13.087
you have first have to ask yourself if
00:31:13.087 --> 00:31:15.424
the product you have is described by any
00:31:15.424 --> 00:31:17.784
of those definitions.
00:31:17.784 --> 00:31:22.350
Okay. So excuse me. A quick note
00:31:22.350 --> 00:31:26.101
on bamboo grain. You can see the first
00:31:26.101 --> 00:31:32.009
product is a horizontal bamboo panel.
00:31:32.009 --> 00:31:34.607
And drawing form, it looks like this up
00:31:34.607 --> 00:31:36.625
in the corner. And you can see the
00:31:36.625 --> 00:31:38.860
grain all runs in the same direction
00:31:38.860 --> 00:31:42.094
here. And this would usually be
00:31:42.094 --> 00:31:44.115
lengthwise down the length of the board.
00:31:44.115 --> 00:31:45.876
Vertical, same thing. You know, you
00:31:45.876 --> 00:31:48.769
can see the little semis in between all
00:31:48.769 --> 00:31:52.535
of the strips. And the grain runs
00:31:52.535 --> 00:31:56.376
lengthwise. But with strand, it's not a
00:31:56.376 --> 00:32:02.355
straight grain. It is kind of wonky.
00:32:02.355 --> 00:32:04.487
There's no actual grain to it, because
00:32:04.487 --> 00:32:07.154
the grains of all the bamboo in it is
00:32:07.154 --> 00:32:08.961
going in all sorts of directions. But
00:32:08.961 --> 00:32:11.433
there is a general direction of grain.
00:32:11.433 --> 00:32:15.161
So if you had like a strand veneer on
00:32:15.161 --> 00:32:19.730
top of engineered flooring, and the wood
00:32:19.730 --> 00:32:22.507
veneers is underneath it, if the grains
00:32:22.507 --> 00:32:24.702
are alternating directions, you know,
00:32:24.702 --> 00:32:27.028
the strand would be lengthwise on top of
00:32:27.028 --> 00:32:33.217
those alternating grains.
00:32:33.217 --> 00:32:35.277
Okay. So let's quickly talk about
00:32:35.277 --> 00:32:37.886
some different kinds of building
00:32:37.886 --> 00:32:42.509
material panels. A panel like this is
00:32:42.509 --> 00:32:45.445
not dedicated. Right? It doesn't have
00:32:45.445 --> 00:32:47.582
any dedicated use for it. It's not
00:32:47.582 --> 00:32:49.362
shaped in any way. It's not finished in
00:32:49.362 --> 00:32:54.144
any way. But it is, and I'm sorry you
00:32:54.144 --> 00:32:56.486
can't totally see this. I can see it,
00:32:56.486 --> 00:32:59.943
because I'm trained for this. But this
00:32:59.943 --> 00:33:03.659
is a 3 layer panel. The top and bottom
00:33:03.659 --> 00:33:08.287
layers are probably 3 to 4-millimeter in
00:33:08.287 --> 00:33:11.508
thickness. And the CORE is around
00:33:11.508 --> 00:33:13.710
7-centimeter in thickness. And the
00:33:13.710 --> 00:33:15.952
grain although natures directions with
00:33:15.952 --> 00:33:19.695
this, the top would be lengthwise, the
00:33:19.695 --> 00:33:22.903
center layer is across wise grain and
00:33:22.903 --> 00:33:26.100
bottom layer is bottom wise grain. So
00:33:26.100 --> 00:33:28.719
this has 3 layers. Outer pliez are
00:33:28.719 --> 00:33:30.939
veneers. The grain of each layer is
00:33:30.939 --> 00:33:33.603
oriented at an angle. And this would
00:33:33.603 --> 00:33:35.244
meet the definition of plywood. So
00:33:35.244 --> 00:33:38.064
heading 4412 for plywood building
00:33:38.064 --> 00:33:41.794
material and similar laminated wood of
00:33:41.794 --> 00:33:44.596
bamboo, it's simple. There's
00:33:44.596 --> 00:33:47.486
classification for bamboo and everything
00:33:47.486 --> 00:33:50.865
else. If you have a similar or
00:33:50.865 --> 00:33:53.238
laminated wood, it goes into other. But
00:33:53.238 --> 00:33:57.677
this one we can classify it under bamboo
00:33:57.677 --> 00:34:08.894
as 4412.500. You can see the lengthwise
00:34:08.894 --> 00:34:11.036
grain goes, you know, off to the right
00:34:11.036 --> 00:34:15.058
on this panel. On the top layer, excuse
00:34:15.058 --> 00:34:17.808
me. The next layer runs cross-wise.
00:34:17.808 --> 00:34:20.374
The next layer runs lengthwise. The
00:34:20.374 --> 00:34:22.894
next layer runs cross-wise and so on.
00:34:22.894 --> 00:34:26.347
It's at least 3 layers. You have
00:34:26.347 --> 00:34:29.684
veneer and grain of each veneer is
00:34:29.684 --> 00:34:31.348
oriented at angle and this is plywood
00:34:31.348 --> 00:34:37.238
also. So 4412.10.500. Now, this one is
00:34:37.238 --> 00:34:42.134
really important, because this is like,
00:34:42.134 --> 00:34:43.522
remember those pictures of the
00:34:43.522 --> 00:34:45.886
horizontal bamboo flooring that I showed
00:34:45.886 --> 00:34:48.688
you. Well, this is not flooring. This
00:34:48.688 --> 00:34:54.661
is, it doesn't have the joinery for
00:34:54.661 --> 00:34:58.886
installation. It's just a dedicated
00:34:58.886 --> 00:35:01.151
wood material. But it has that same
00:35:01.151 --> 00:35:03.020
horizontal construction. It's got 3
00:35:03.020 --> 00:35:06.046
layers, each layer is made of strips
00:35:06.046 --> 00:35:08.417
glued side-by-side and basically forming
00:35:08.417 --> 00:35:10.287
a veneer, because it's less than 6
00:35:10.287 --> 00:35:12.101
millimeters, it's probably 5
00:35:12.101 --> 00:35:15.787
millimeters. And in 3 layers. And the
00:35:15.787 --> 00:35:18.698
important thing is that all 3 of these
00:35:18.698 --> 00:35:21.671
layers, the grain runs the length of the
00:35:21.671 --> 00:35:24.834
board. They're all lengthwise. So even
00:35:24.834 --> 00:35:27.806
though it's 3 layers, the grains don't
00:35:27.806 --> 00:35:29.946
alternate directions. Right? So
00:35:29.946 --> 00:35:31.806
they're all parallel.
00:35:31.806 --> 00:35:34.055
And because they don't alternate
00:35:34.055 --> 00:35:36.525
directions, they can't be plywood.
00:35:36.525 --> 00:35:39.213
Right? So the only other option here,
00:35:39.213 --> 00:35:41.897
because your top layer constitutes a
00:35:41.897 --> 00:35:44.617
veneer, it's less than 6 millimeters in
00:35:44.617 --> 00:35:47.295
thickness and it's a sheet of wood, this
00:35:47.295 --> 00:35:52.474
is actually a veneered panel. Not an
00:35:52.474 --> 00:35:56.355
assemble flooring panel, but it's a
00:35:56.355 --> 00:35:58.717
veneer, just non-descript panel. So
00:35:58.717 --> 00:36:02.825
like I said, 4412 is for bamboo very
00:36:02.825 --> 00:36:05.276
limited. You have a choice of plywood
00:36:05.276 --> 00:36:07.066
or other and this would be other,
00:36:07.066 --> 00:36:13.634
because veneers panels are in other. So
00:36:13.634 --> 00:36:15.116
4,412.10.9000 for that panel. But
00:36:15.116 --> 00:36:20.091
flooring is where the most of your
00:36:20.091 --> 00:36:21.566
bamboo products are going to fall so,
00:36:21.566 --> 00:36:25.102
there are 4 main constructions of bamboo
00:36:25.102 --> 00:36:25.548
flooring.
00:36:25.548 --> 00:36:27.285
I showed you the horizontal before.
00:36:27.285 --> 00:36:30.074
You can see the strips side by side and
00:36:30.074 --> 00:36:32.647
in 3 layers. The vertical, you can see
00:36:32.647 --> 00:36:36.524
the strips side-by-side. Engineered is
00:36:36.524 --> 00:36:42.246
a veneer over a plywood substrate,
00:36:42.246 --> 00:36:45.218
usually a wood, like tree-type wood.
00:36:45.218 --> 00:36:48.779
And then strand woven, don't get hung
00:36:48.779 --> 00:36:58.833
up on the word woven. You can see the
00:36:58.833 --> 00:37:00.162
construction in the cross-section and
00:37:00.162 --> 00:37:02.300
that's how you're able to identify the
00:37:02.300 --> 00:37:03.650
construction for classification
00:37:03.650 --> 00:37:05.319
purposes.
00:37:05.319 --> 00:37:07.132
Okay. Here's the next funny break.
00:37:07.132 --> 00:37:09.077
I had to put this in, because it
00:37:09.077 --> 00:37:11.399
cracked me up so bad, I could have died.
00:37:11.399 --> 00:37:14.228
[Laughter] two guys standing at the
00:37:14.228 --> 00:37:18.888
door looking at the floor, you know,
00:37:18.888 --> 00:37:21.659
pandas that have ambushed the room
00:37:21.659 --> 00:37:23.892
ripping up the bamboo flooring and
00:37:23.892 --> 00:37:27.917
eating it. And this is the precise
00:37:27.917 --> 00:37:31.790
reason I didn't want bamboo flooring.
00:37:31.790 --> 00:37:33.773
I would be so torn. I would think
00:37:33.773 --> 00:37:37.432
it's so awesome that a bunch of pandas
00:37:37.432 --> 00:37:39.282
broke into my house. But that's just
00:37:39.282 --> 00:37:41.022
me. [Laughter]
00:37:41.022 --> 00:37:45.468
Okay. So for flooring, first thing
00:37:45.468 --> 00:37:47.274
I want to talk to you about is
00:37:47.274 --> 00:37:50.237
multilayer flooring. So multiple
00:37:50.237 --> 00:37:52.394
layers, when you look at that
00:37:52.394 --> 00:37:55.196
cross-section, okay? So when you have
00:37:55.196 --> 00:37:57.321
multilayer flooring, you're going to
00:37:57.321 --> 00:38:00.446
have two possible headings where these
00:38:00.446 --> 00:38:03.673
things are classified in. One is 4412,
00:38:03.673 --> 00:38:06.696
plywood veneer panel or similar or
00:38:06.696 --> 00:38:09.821
laminated wood and one is 4418,
00:38:09.821 --> 00:38:11.824
builders' joinery. And the difference
00:38:11.824 --> 00:38:14.163
in classifying in one versus the other,
00:38:14.163 --> 00:38:15.845
because you wouldn't have any idea what
00:38:15.845 --> 00:38:17.619
would make them go in one versus the
00:38:17.619 --> 00:38:20.184
other, but naturally, by the language
00:38:20.184 --> 00:38:23.388
and the tariff. But there is an actual
00:38:23.388 --> 00:38:24.934
note in the tariff's schedule.
00:38:24.934 --> 00:38:29.169
Additional U.S. note 4 (b) that states
00:38:29.169 --> 00:38:32.320
heading 4418 includes multilayer
00:38:32.320 --> 00:38:35.144
assembled flooring panels having a face
00:38:35.144 --> 00:38:38.359
ply 4 millimeters or more in thickness.
00:38:38.359 --> 00:38:41.989
I don't know why this rule is here.
00:38:41.989 --> 00:38:44.730
But nonetheless, it is, and it's the
00:38:44.730 --> 00:38:48.919
statute. It's law. So if you have a
00:38:48.919 --> 00:38:51.608
multilayer assembled flooring panel and
00:38:51.608 --> 00:38:54.501
we'll talk about what assembled flooring
00:38:54.501 --> 00:38:56.335
panel means in a second and it has a
00:38:56.335 --> 00:39:00.994
face ply of less than 4mm, it goes in
00:39:00.994 --> 00:39:05.440
4412. If it has 4mM or more, it goes in
00:39:05.440 --> 00:39:06.325
4418.
00:39:06.325 --> 00:39:09.319
And in a very important note about
00:39:09.319 --> 00:39:13.960
that 4mm measurement, classification is
00:39:13.960 --> 00:39:17.771
based on a product and its condition as
00:39:17.771 --> 00:39:21.224
imported. So we're talking about actual
00:39:21.224 --> 00:39:24.275
thickness of that face ply. I see this
00:39:24.275 --> 00:39:29.081
all the time. The invoice says 4mm face
00:39:29.081 --> 00:39:33.175
ply. But what happened is they put 4mm
00:39:33.175 --> 00:39:34.507
veneer on top of the flooring substrate
00:39:34.507 --> 00:39:37.239
and they sanded it and finished it. So
00:39:37.239 --> 00:39:40.125
it's no longer 4mm in thickness. That
00:39:40.125 --> 00:39:43.877
means the product is in 4412. Like this
00:39:43.877 --> 00:39:46.102
picture here is exactly one of those
00:39:46.102 --> 00:39:48.793
examples. And unfortunately, you can't
00:39:48.793 --> 00:39:51.025
really see this so well on my little,
00:39:51.025 --> 00:39:55.446
you know, old fashion caliper. But this
00:39:55.446 --> 00:40:00.612
face ply only measures 3.35mm thickness.
00:40:00.612 --> 00:40:04.087
So it has to go into 4412. So you need
00:40:04.087 --> 00:40:06.007
to be aware of your products. And when
00:40:06.007 --> 00:40:08.154
I say this happened several times, it's
00:40:08.154 --> 00:40:10.138
happened a lot where I've caught the
00:40:10.138 --> 00:40:11.813
same problem.
00:40:11.813 --> 00:40:13.673
So your product is only classified
00:40:13.673 --> 00:40:17.752
in 4418 if it is exactly 4mm or thicker.
00:40:17.752 --> 00:40:23.156
Okay? Really important. Okay.
00:40:23.156 --> 00:40:26.742
So 4418, like I said is for
00:40:26.742 --> 00:40:28.214
recognizable articles used in the
00:40:28.214 --> 00:40:30.529
construction of a building. So that's
00:40:30.529 --> 00:40:33.110
the easy part. The language of the
00:40:33.110 --> 00:40:35.768
heading, you can see there it says
00:40:35.768 --> 00:40:39.777
builders' joinery and carpentry of wood,
00:40:39.777 --> 00:40:41.798
including cellular wood panels and
00:40:41.798 --> 00:40:43.677
assembled flooring panels. Well, it's
00:40:43.677 --> 00:40:45.956
kind of redundant to put assembled
00:40:45.956 --> 00:40:47.826
flooring panels in there, because the
00:40:47.826 --> 00:40:50.906
builders' joinery by definition includes
00:40:50.906 --> 00:40:53.251
flooring panels, as the articles used in
00:40:53.251 --> 00:40:55.367
the construction of the building. But
00:40:55.367 --> 00:40:57.688
be assembled flooring panels are
00:40:57.688 --> 00:41:01.099
specifically named. And you do have to
00:41:01.099 --> 00:41:04.758
know about this for classification.
00:41:04.758 --> 00:41:11.230
What's meant by assembled flooring
00:41:11.230 --> 00:41:13.901
panels is a panel made from distinct
00:41:13.901 --> 00:41:16.709
pieces or parts of wood that are
00:41:16.709 --> 00:41:19.004
deliberately joined and fitted together
00:41:19.004 --> 00:41:21.652
in ordered manner to form a whole panel.
00:41:21.652 --> 00:41:26.850
Okay? So this can include layers. So
00:41:26.850 --> 00:41:29.054
an engineered flooring panel with
00:41:29.054 --> 00:41:34.441
multiple wood veneer layers, those are
00:41:34.441 --> 00:41:38.540
distinct pieces. Strips, like what
00:41:38.540 --> 00:41:40.081
bamboo is made of, those are distinct
00:41:40.081 --> 00:41:42.554
pieces. You know, you put them
00:41:42.554 --> 00:41:46.947
side-by-side, or in layers. And shapes
00:41:46.947 --> 00:41:54.673
to form a pattern, like parkay.
00:41:54.673 --> 00:41:59.497
Parquet. Those are distinct pieces
00:41:59.497 --> 00:42:02.174
also. So if it's made of layers or
00:42:02.174 --> 00:42:06.095
strips, or shapes, specific shapes, then
00:42:06.095 --> 00:42:10.592
it is an assembled flooring panel.
00:42:10.592 --> 00:42:14.260
Strand bamboo, not assembled. It is
00:42:14.260 --> 00:42:17.647
not an assembled flooring panel.
00:42:17.647 --> 00:42:20.085
Because if you look at it, you can see
00:42:20.085 --> 00:42:21.911
in the cross-section, there are no
00:42:21.911 --> 00:42:30.223
distinct shapes. It's just randomly
00:42:30.223 --> 00:42:33.085
shredded bamboo expressed into a block.
00:42:33.085 --> 00:42:34.796
It's not distinct pieces. It's not
00:42:34.796 --> 00:42:36.923
assembled together. It's not ordered.
00:42:36.923 --> 00:42:40.860
It's just like mush. Right? So when
00:42:40.860 --> 00:42:44.846
you see the term pp assembled flooring
00:42:44.846 --> 00:42:48.395
panels, it's going to apply to some
00:42:48.395 --> 00:42:50.409
bamboo products, but not all of them.
00:42:50.409 --> 00:42:53.771
So strand bamboo is not assembled
00:42:53.771 --> 00:42:55.282
flooring panel.
00:42:55.282 --> 00:43:00.167
Okay. So here's that picture again.
00:43:00.167 --> 00:43:01.879
You can see the horizontal and
00:43:01.879 --> 00:43:03.431
individual strips glued together. You
00:43:03.431 --> 00:43:05.477
can see the individual layers glued
00:43:05.477 --> 00:43:06.967
together. This is assembled. The
00:43:06.967 --> 00:43:09.655
vertical, you can see the strips glued
00:43:09.655 --> 00:43:13.329
side-by-side. This is assembled. For
00:43:13.329 --> 00:43:16.272
engineered, even in this case, where the
00:43:16.272 --> 00:43:21.352
top veneer, the bamboo veneer is
00:43:21.352 --> 00:43:25.332
strand, the overall construction of the
00:43:25.332 --> 00:43:30.135
panel is specific assembled layers. So
00:43:30.135 --> 00:43:39.161
we will call this an assembled flooring
00:43:39.161 --> 00:43:41.285
panels. When you look at the side of
00:43:41.285 --> 00:43:44.629
it, this is isn't the best example to
00:43:44.629 --> 00:43:48.119
see it. But you can kind of see like
00:43:48.119 --> 00:43:53.687
clumps of bamboo in there. And that's
00:43:53.687 --> 00:43:57.147
more of, you know, it's almost a better
00:43:57.147 --> 00:44:02.114
description than any kind of solid.
00:44:02.114 --> 00:44:05.089
Okay. So when you have engineered
00:44:05.089 --> 00:44:08.077
bamboo flooring, meaning a layer of
00:44:08.077 --> 00:44:10.826
bamboo veneer over a plywood
00:44:10.826 --> 00:44:13.711
construction substrate, these are
00:44:13.711 --> 00:44:16.443
usually going to be, you know, at least
00:44:16.443 --> 00:44:23.641
5 layers of wood. Sometimes 7, 9, 11.
00:44:23.641 --> 00:44:27.189
And the grain of each layer is oriented
00:44:27.189 --> 00:44:30.665
at an angle to that of adjacent layers.
00:44:30.665 --> 00:44:33.825
This is implied wood construction. And
00:44:33.825 --> 00:44:36.303
it's also an assembled flooring panel.
00:44:36.303 --> 00:44:42.263
Okay? So if the face ply is less than
00:44:42.263 --> 00:44:45.108
4mm in thickness, it stays in 4412 and
00:44:45.108 --> 00:44:47.144
it's classified as plywood, because it
00:44:47.144 --> 00:44:50.290
meets that definition of plywood.
00:44:50.290 --> 00:44:56.113
If it's more than 4mm. So 4mm more
00:44:56.113 --> 00:44:59.384
in thickness, then it goes into 4418.
00:44:59.384 --> 00:45:01.502
And here's just an actual picture of a
00:45:01.502 --> 00:45:03.399
product that I had at my desk where you
00:45:03.399 --> 00:45:07.321
can see the bamboo top layer, and the
00:45:07.321 --> 00:45:10.659
plywood substrate, where the grains of
00:45:10.659 --> 00:45:12.997
wood running in different directions.
00:45:12.997 --> 00:45:18.777
This is 4412.10.500 as plywood. This
00:45:18.777 --> 00:45:21.759
is another plywood construction panel.
00:45:21.759 --> 00:45:24.666
This is your similar laminated wood.
00:45:24.666 --> 00:45:28.087
This is block board. And it has a
00:45:28.087 --> 00:45:32.030
veneer face, a veneer back and a core of
00:45:32.030 --> 00:45:35.168
lumber. And it happens that this one,
00:45:35.168 --> 00:45:38.622
the grains alternate directions. So
00:45:38.622 --> 00:45:44.921
this actually meets the definition of
00:45:44.921 --> 00:45:47.440
plywood. Because this is more specific
00:45:47.440 --> 00:45:49.575
than similar or laminated wood. So if
00:45:49.575 --> 00:45:53.023
the plywood is less than 4-millimeter,
00:45:53.023 --> 00:45:55.528
this meets the definition in 4412. If
00:45:55.528 --> 00:45:58.867
it's more than 4mm in thickness, it goes
00:45:58.867 --> 00:46:01.971
into 4418. Okay. So here are those
00:46:01.971 --> 00:46:03.489
constructions again. Horizontal,
00:46:03.489 --> 00:46:07.606
vertical, strand. Okay? Assembled,
00:46:07.606 --> 00:46:11.105
assembled, not assembled.
00:46:11.105 --> 00:46:13.851
Okay. So let's talk first about
00:46:13.851 --> 00:46:16.669
horizontal bamboo flooring. Horizontal
00:46:16.669 --> 00:46:21.295
bamboo flooring is assembled, and it's
00:46:21.295 --> 00:46:24.843
multilayer. It has 3 layers. 1, 2, 3.
00:46:24.843 --> 00:46:39.278
Okay horizontal bamboo flooring is less
00:46:39.278 --> 00:46:42.690
than 6mm in thickness. If that top
00:46:42.690 --> 00:46:46.040
layer is less than 4mm in thickness,
00:46:46.040 --> 00:46:48.714
then you can put it in 4412. But thing
00:46:48.714 --> 00:46:51.696
is that with horizontal bamboo flooring,
00:46:51.696 --> 00:46:54.537
the top layer is almost always 5
00:46:54.537 --> 00:46:57.890
millimeters, like exactly. It's uncanny
00:46:57.890 --> 00:46:59.534
how accurate it is.
00:46:59.534 --> 00:47:03.578
So if it's 5mm, it's over that 4mm
00:47:03.578 --> 00:47:06.600
mark, and it automatically goes into
00:47:06.600 --> 00:47:12.433
4418. And remember that note says
00:47:12.433 --> 00:47:14.794
assembled, multilayer flooring panels
00:47:14.794 --> 00:47:17.952
with a face ply of 4mm or more in
00:47:17.952 --> 00:47:21.248
thickness go into 4418. So if this
00:47:21.248 --> 00:47:24.266
happens to have a face ply of less than
00:47:24.266 --> 00:47:26.534
4mms, which probably doesn't, then it
00:47:26.534 --> 00:47:33.552
would go into veneer panels in
00:47:33.552 --> 00:47:35.125
4,412.10.9000. But chances are you're
00:47:35.125 --> 00:47:37.023
not going to see this. You're not going
00:47:37.023 --> 00:47:40.461
to see a horizontal bamboo flooring
00:47:40.461 --> 00:47:44.878
panel. What you're going to see is a
00:47:44.878 --> 00:47:47.015
4418 bamboo flooring panel. So it's
00:47:47.015 --> 00:47:50.517
multilayer. It's assembled. The face
00:47:50.517 --> 00:47:54.074
replay is almost 5mM thick. And per
00:47:54.074 --> 00:47:58.519
U.S. note, it's 4 (b) and classified in
00:47:58.519 --> 00:48:00.621
4418. Just a quick note. Additional
00:48:00.621 --> 00:48:07.018
U.S. note 4 (b) was 5 (b) last year and
00:48:07.018 --> 00:48:10.470
I don't know why it keeps switching
00:48:10.470 --> 00:48:12.931
around. But right now it's 4 (b). So
00:48:12.931 --> 00:48:14.386
you can see the language of the
00:48:14.386 --> 00:48:16.212
subheading here. There does actually a
00:48:16.212 --> 00:48:18.515
breakout for p assembly flooring panel.
00:48:18.515 --> 00:48:20.223
So this is why we need to be aware of
00:48:20.223 --> 00:48:27.927
that.
00:48:27.927 --> 00:48:30.147
So before we finish this up, I'm
00:48:30.147 --> 00:48:35.377
going to bring up uni-directional. I
00:48:35.377 --> 00:48:39.034
don't know why the WCO landed on this
00:48:39.034 --> 00:48:41.758
particular language. But
00:48:41.758 --> 00:48:44.861
uni-directional, actually, I have to go
00:48:44.861 --> 00:48:46.050
back and check that if it's
00:48:46.050 --> 00:48:48.751
international or just domestic. But
00:48:48.751 --> 00:48:51.614
uni-directional bamboo means that the
00:48:51.614 --> 00:48:54.632
grain of all of the pieces of bamboo in
00:48:54.632 --> 00:48:56.556
that product are running the same
00:48:56.556 --> 00:49:01.289
direction. Okay? Horizontal bamboo
00:49:01.289 --> 00:49:04.327
flooring is made of several pieces,
00:49:04.327 --> 00:49:09.239
several strips of wood, side-by-side,
00:49:09.239 --> 00:49:10.775
and everywhere layers of it, and every
00:49:10.775 --> 00:49:12.896
single piece that grain is running the
00:49:12.896 --> 00:49:19.001
length of the panel. It's parallel.
00:49:19.001 --> 00:49:21.411
All-in-one direction. That's
00:49:21.411 --> 00:49:23.534
uni-directional bamboo. So the center
00:49:23.534 --> 00:49:25.674
picture is actually a picture of a piece
00:49:25.674 --> 00:49:28.434
of bamboo plywood. You can see the
00:49:28.434 --> 00:49:30.902
grain runs one direction in the top
00:49:30.902 --> 00:49:35.057
layer. It runs a different direction in
00:49:35.057 --> 00:49:36.863
the CORE, and runs a different direction
00:49:36.863 --> 00:49:39.183
on the bottom layer. This is not
00:49:39.183 --> 00:49:40.911
uni-directional. It's not all running
00:49:40.911 --> 00:49:42.521
in the same direction.
00:49:42.521 --> 00:49:44.175
And then strand, although this is
00:49:44.175 --> 00:49:46.335
not going to come up, but strand would
00:49:46.335 --> 00:49:48.450
not be uni-directional, because the
00:49:48.450 --> 00:49:51.033
grains are all wonky and goes in
00:49:51.033 --> 00:49:53.797
different directions.
00:49:53.797 --> 00:49:57.510
Okay. So here's the actual tariff
00:49:57.510 --> 00:50:01.844
for horizontal bamboo flooring panels.
00:50:01.844 --> 00:50:04.443
So we know they're assembled. We know
00:50:04.443 --> 00:50:07.970
they're multilayer. They're of bamboo.
00:50:07.970 --> 00:50:12.316
So your choices are for mosaic floors
00:50:12.316 --> 00:50:16.033
and other multilayer. Horizontal is not
00:50:16.033 --> 00:50:19.398
mosaic. It's just strips side-by-side.
00:50:19.398 --> 00:50:22.198
Other is appropriate 679 and it's
00:50:22.198 --> 00:50:24.147
multilayer, and there's 3 layers, and
00:50:24.147 --> 00:50:28.448
you can see it has face ply more than
00:50:28.448 --> 00:50:32.524
6mm or other and we go with other and of
00:50:32.524 --> 00:50:33.558
uni-directional bamboo, because the
00:50:33.558 --> 00:50:37.423
grain of each strip in that horizontal
00:50:37.423 --> 00:50:39.221
panel run in the same direction. So
00:50:39.221 --> 00:50:46.378
horizontal bamboo flooring, 4418,
00:50:46.378 --> 00:50:49.155
763,000. So vertical flooring. They
00:50:49.155 --> 00:50:52.373
recall flooring cannot be classified in
00:50:52.373 --> 00:50:54.251
4412. And, hopefully, you already
00:50:54.251 --> 00:50:56.465
figured out why this can't be. But I
00:50:56.465 --> 00:50:59.386
will tell you anyway. There are some
00:50:59.386 --> 00:51:02.120
rulings out there in cross that put
00:51:02.120 --> 00:51:04.450
seller bamboo flooring in 4412 and those
00:51:04.450 --> 00:51:08.928
are being revoked, because plywood,
00:51:08.928 --> 00:51:11.114
veneer panels, and similar laminated
00:51:11.114 --> 00:51:12.942
wood all have one thing in common.
00:51:12.942 --> 00:51:16.592
They're all multilayer. Right?
00:51:16.592 --> 00:51:18.363
Vertical is not multilayer. It's only
00:51:18.363 --> 00:51:21.475
one layer. Just one layer of strip
00:51:21.475 --> 00:51:24.883
side-by-side. Okay? So plywood has to
00:51:24.883 --> 00:51:27.900
have at least 3 layers. Veneer panel is
00:51:27.900 --> 00:51:30.596
a veneer affixed to a base that has two
00:51:30.596 --> 00:51:34.741
layers. And similar laminated wood is
00:51:34.741 --> 00:51:37.464
at least 3 layers. So vertical cannot
00:51:37.464 --> 00:51:42.461
go under 4412. It is a recognizable
00:51:42.461 --> 00:51:43.658
article used in the construction of a
00:51:43.658 --> 00:51:47.441
building so it goes into 4418.
00:51:47.441 --> 00:51:50.784
So it is assembled. It's not
00:51:50.784 --> 00:51:53.362
multilayer. So we still are classifying
00:51:53.362 --> 00:51:55.797
in that subheading for assembled
00:51:55.797 --> 00:52:00.279
flooring panels. Okay? So we have
00:52:00.279 --> 00:52:04.186
assembled flooring panel of bamboo.
00:52:04.186 --> 00:52:08.005
Great. Your choices are for mow sake
00:52:08.005 --> 00:52:11.110
floor, other multilayer, other. It's
00:52:11.110 --> 00:52:13.684
not multilayer. It's just strips.
00:52:13.684 --> 00:52:15.826
Others, but not multilayer and single
00:52:15.826 --> 00:52:21.240
layer. So we go down to other.
00:52:21.240 --> 00:52:25.768
4,418.37.9000 for vertical bamboo. And
00:52:25.768 --> 00:52:28.466
strand, remember it's not assembled,
00:52:28.466 --> 00:52:31.354
right? So it can't be classified under
00:52:31.354 --> 00:52:33.807
that subheading language for assembled
00:52:33.807 --> 00:52:36.269
flooring panel. Right? So remember
00:52:36.269 --> 00:52:38.860
here we have assembled flooring panels.
00:52:38.860 --> 00:52:40.498
You see that? We can't put strand
00:52:40.498 --> 00:52:44.632
there. Okay. So strand basically drops
00:52:44.632 --> 00:52:48.074
down to other. And then of bamboo. And
00:52:48.074 --> 00:52:49.743
there's a few choices there. We go to
00:52:49.743 --> 00:52:51.192
other, and there's a breakout
00:52:51.192 --> 00:52:55.808
specifically for wood flooring. So
00:52:55.808 --> 00:53:06.458
strand bamboo flooring, 4418.91.1905.
00:53:06.458 --> 00:53:08.632
[Rewriting] 9105.
00:53:08.632 --> 00:53:10.590
So here's another picture of strand
00:53:10.590 --> 00:53:12.521
bamboo flooring so you can see better
00:53:12.521 --> 00:53:15.962
that it's not assembled. It's just like
00:53:15.962 --> 00:53:20.484
a random, you know, block of strips down
00:53:20.484 --> 00:53:23.536
shoved together. So there's no
00:53:23.536 --> 00:53:27.603
deliberate assembly there.
00:53:27.603 --> 00:53:33.972
Do you know what you get when you
00:53:33.972 --> 00:53:44.028
cross a deer and a ghost? Bamboo! Deer
00:53:44.028 --> 00:53:48.371
and ghost, bamboo. Okay, I'm not going
00:53:48.371 --> 00:53:50.450
to go into deep classification of bamboo
00:53:50.450 --> 00:53:52.947
moldings because horizontal ones can
00:53:52.947 --> 00:53:55.418
sometimes end up in 4412. But for the
00:53:55.418 --> 00:53:58.703
most part, bamboo moldings are going to
00:53:58.703 --> 00:54:06.861
be just other builders joinery.
00:54:06.861 --> 00:54:13.492
4418.19.9195. Now, moldings have a
00:54:13.492 --> 00:54:17.135
decorative aspect to them. They're
00:54:17.135 --> 00:54:19.829
functional, but they're not structural.
00:54:19.829 --> 00:54:22.586
And so sometimes you will see things
00:54:22.586 --> 00:54:25.381
like stair noses. And those are
00:54:25.381 --> 00:54:27.656
structural and they're not moldings,
00:54:27.656 --> 00:54:29.956
but they're classified in the same way,
00:54:29.956 --> 00:54:37.262
just so you know. Generally speaking,
00:54:37.262 --> 00:54:42.592
this is what you run into.
00:54:42.592 --> 00:54:46.857
4,418.73.6000. Vertical is
00:54:46.857 --> 00:54:53.682
4,418.37.9000. Strand is 4418.19.9105.
00:54:53.682 --> 00:55:04.127
And New Jerseyered is 4412.10.0500.
00:55:04.127 --> 00:55:06.998
And just, I just have to talk about
00:55:06.998 --> 00:55:11.136
this, because if you go into the custom
00:55:11.136 --> 00:55:13.009
rules online search system and you try
00:55:13.009 --> 00:55:16.148
to find a ruling for vertical bamboo
00:55:16.148 --> 00:55:18.510
flooring, and you come across one,
00:55:18.510 --> 00:55:21.344
maybe it's from 2013 or something like
00:55:21.344 --> 00:55:24.721
that and the code that's on it no longer
00:55:24.721 --> 00:55:27.082
exists, right? And you're thinking,
00:55:27.082 --> 00:55:29.171
okay, I guess the ruling is no longer
00:55:29.171 --> 00:55:32.433
valid? Like what happened?
00:55:32.433 --> 00:55:37.194
So it is still valid. The tariff
00:55:37.194 --> 00:55:38.905
schedule change overtime. It change
00:55:38.905 --> 00:55:40.453
internationally. It change
00:55:40.453 --> 00:55:42.580
domestically. And we see it at least
00:55:42.580 --> 00:55:47.922
once a year, you know, excuse me, the
00:55:47.922 --> 00:55:50.563
tariff schedule change domestically
00:55:50.563 --> 00:55:54.128
twice a year. And with additional
00:55:54.128 --> 00:55:59.447
updates, and international tariff level
00:55:59.447 --> 00:56:03.428
chambers every 5 years. The important
00:56:03.428 --> 00:56:06.656
thing to know, to realize is that we
00:56:06.656 --> 00:56:10.275
don't classify by the codes. The
00:56:10.275 --> 00:56:12.718
general rules of interpretation tell you
00:56:12.718 --> 00:56:16.459
that classification is based on the
00:56:16.459 --> 00:56:19.059
language of the headings and the notes.
00:56:19.059 --> 00:56:21.826
And of course the subheadings as well.
00:56:21.826 --> 00:56:24.405
But the headings and the notes, you're
00:56:24.405 --> 00:56:27.173
classifying by the language, not by the
00:56:27.173 --> 00:56:30.317
number. Okay? You find your product's
00:56:30.317 --> 00:56:33.190
description, and then you take the
00:56:33.190 --> 00:56:35.523
corresponding number and use that as the
00:56:35.523 --> 00:56:36.535
classification.
00:56:36.535 --> 00:56:38.504
So you're looking around for, you
00:56:38.504 --> 00:56:44.374
know, 4418.72.1900 and it's not there
00:56:44.374 --> 00:56:46.238
anymore, but the exact same language is
00:56:46.238 --> 00:56:50.692
still there. So the ruling, which has
00:56:50.692 --> 00:56:53.593
the language, the tariff language in it,
00:56:53.593 --> 00:56:57.178
word-for-word, verbatim, that language,
00:56:57.178 --> 00:57:03.574
if you go into the tariff schedule today
00:57:03.574 --> 00:57:05.159
and that language, you will find the
00:57:05.159 --> 00:57:06.761
correct code. Just so you know,
00:57:06.761 --> 00:57:09.283
sometimes the language does change, but
00:57:09.283 --> 00:57:11.670
look for the same language of that
00:57:11.670 --> 00:57:16.221
ruling, and you'll most likely find your
00:57:16.221 --> 00:57:17.791
correct classification. So you can see
00:57:17.791 --> 00:57:20.795
here in 2016, horizontal bamboo flooring
00:57:20.795 --> 00:57:31.068
was 4418.72.9100. Now it's 44 p
00:57:31.068 --> 00:57:32.359
18.73.7000 but the language is exactly
00:57:32.359 --> 00:57:35.018
the same. Couple of more panel really
00:57:35.018 --> 00:57:37.326
quickly. This is a vertical panel.
00:57:37.326 --> 00:57:39.809
It's not flooring. It does not have the
00:57:39.809 --> 00:57:42.131
joinery to install as flooring, it's not
00:57:42.131 --> 00:57:43.797
finished as flooring. It's just a
00:57:43.797 --> 00:57:48.893
multi-use material. So it's not
00:57:48.893 --> 00:57:52.888
flooring. It's not a recognizable
00:57:52.888 --> 00:57:54.802
article used in the construction of the
00:57:54.802 --> 00:57:56.898
building. It's basically just a board.
00:57:56.898 --> 00:57:59.490
It has no dedicated purpose for it. So
00:57:59.490 --> 00:58:02.878
you can't put it in 4418. Because 4418
00:58:02.878 --> 00:58:05.356
has to be a recognizable article used in
00:58:05.356 --> 00:58:07.187
the construction of the building.
00:58:07.187 --> 00:58:10.227
So it automatically just advances to
00:58:10.227 --> 00:58:13.490
other articles of wood. 4421. And this
00:58:13.490 --> 00:58:15.713
kind of construction, the best
00:58:15.713 --> 00:58:22.034
description is edge-glued lumber. So
00:58:22.034 --> 00:58:26.146
4421.19.9400 for a vertical just
00:58:26.146 --> 00:58:29.667
building panel. Strand is the same
00:58:29.667 --> 00:58:31.513
thing. It's not a recognizable article
00:58:31.513 --> 00:58:32.616
used in the construction of the
00:58:32.616 --> 00:58:36.139
building. It's just a board. And this
00:58:36.139 --> 00:58:38.041
construction is not provided for
00:58:38.041 --> 00:58:40.350
anywhere else in the tariff's schedule.
00:58:40.350 --> 00:58:44.326
So it's other article of wood, just
00:58:44.326 --> 00:58:46.237
completely other, other, other. You
00:58:46.237 --> 00:58:53.353
know? S 4421.91.9880. And there are
00:58:53.353 --> 00:58:55.046
all kinds of random different
00:58:55.046 --> 00:58:57.672
constructions of bamboo out there. If
00:58:57.672 --> 00:59:00.125
you have one of them, I highly recommend
00:59:00.125 --> 00:59:02.582
that you get a binding ruling on them
00:59:02.582 --> 00:59:05.033
so you know where they're correctly
00:59:05.033 --> 00:59:06.673
classified. I'm happy to put those in
00:59:06.673 --> 00:59:09.461
writing, because I like to see more
00:59:09.461 --> 00:59:13.389
constructions and more usage. If one of
00:59:13.389 --> 00:59:15.975
these happen to be like a post or beam
00:59:15.975 --> 00:59:18.307
used in construction of the building, it
00:59:18.307 --> 00:59:22.598
could be 4418, it could be 4412, or
00:59:22.598 --> 00:59:24.583
4421. So I encourage you to request a
00:59:24.583 --> 00:59:25.844
binding ruling for these.
00:59:25.844 --> 00:59:28.583
And you made it! You made it all
00:59:28.583 --> 00:59:30.386
the way through. So, hopefully, that
00:59:30.386 --> 00:59:31.712
clarified things a little bit for you.
00:59:31.712 --> 00:59:34.456
Like I said, if not, you have my email
00:59:34.456 --> 00:59:38.252
address, and you can always ask me. And
00:59:38.252 --> 00:59:42.439
let's move on to the chat box and see if
00:59:42.439 --> 00:59:44.878
anybody had questions while we were
00:59:44.878 --> 00:59:49.812
going through this.
00:59:49.812 --> 00:59:51.289
>> CHRISSI GUTH: So few questions
00:59:51.289 --> 00:59:52.708
came in earlier.
00:59:52.708 --> 00:59:53.431
>> SANDRA WALIA: One of them give
00:59:53.431 --> 00:59:55.697
or two that were input by the same
00:59:55.697 --> 01:00:00.495
person. This person says 5mm3 layer was
01:00:00.495 --> 01:00:04.239
4412. This contradicts note 4 (b).
01:00:04.239 --> 01:00:05.190
>> LAUREL DUVALL: No, that's not
01:00:05.190 --> 01:00:07.876
what I said. If it happens to be that
01:00:07.876 --> 01:00:12.431
the top layer is less than 4mm, then it
01:00:12.431 --> 01:00:16.869
goes into 4412. But generally speaking,
01:00:16.869 --> 01:00:20.444
it's almost always 5mm. Which means it
01:00:20.444 --> 01:00:24.876
goes into 4418. So sorry that there was
01:00:24.876 --> 01:00:28.435
some sort of confusion there. But if
01:00:28.435 --> 01:00:32.224
it's 5mm, like you noted with additional
01:00:32.224 --> 01:00:36.553
U.S. note 4 (b) it goes into 4418 if it
01:00:36.553 --> 01:00:39.530
has a 5mm face ply.
01:00:39.530 --> 01:00:40.569
>> SANDRA WALIA: Okay, great.
01:00:40.569 --> 01:00:43.270
Another question was can a plywood with
01:00:43.270 --> 01:00:51.151
veneer face and backing fall under
01:00:51.151 --> 01:00:55.047
44911? 4411?
01:00:55.047 --> 01:00:57.890
>> SANDRA WALIA: Yeah. Probably.
01:00:57.890 --> 01:01:00.565
>> LAUREL DUVALL: Okay, 4411 don't
01:01:00.565 --> 01:01:06.993
exist. But 44 are 911 is printed
01:01:06.993 --> 01:01:10.105
matter. 4411. This is for fiber board
01:01:10.105 --> 01:01:12.763
products. And once you put a veneer on
01:01:12.763 --> 01:01:21.854
top of fiber board it becomes a fiber
01:01:21.854 --> 01:01:24.856
panel. The wood layer gives the panel
01:01:24.856 --> 01:01:27.217
its essential character. So you're not
01:01:27.217 --> 01:01:30.779
going to ever classify a veneer product
01:01:30.779 --> 01:01:33.297
in 4411.
01:01:33.297 --> 01:01:34.071
>> SANDRA WALIA: Okay. Next
01:01:34.071 --> 01:01:35.753
question, do you need a sample for
01:01:35.753 --> 01:01:38.733
ruling? If so, how big of a piece?
01:01:38.733 --> 01:01:39.775
>> LAUREL DUVALL: I do prefer
01:01:39.775 --> 01:01:41.798
samples for rulings. It's just easier
01:01:41.798 --> 01:01:44.227
for me to answer my own questions about
01:01:44.227 --> 01:01:47.839
it. Sometimes I think when people
01:01:47.839 --> 01:01:51.199
request rulings, they don't understand
01:01:51.199 --> 01:01:54.193
what we're looking for, because there
01:01:54.193 --> 01:01:56.157
are details for their concerns of the
01:01:56.157 --> 01:01:59.190
product are not important, but they're
01:01:59.190 --> 01:02:00.289
important for classification so, I
01:02:00.289 --> 01:02:01.618
prefer a sample.
01:02:01.618 --> 01:02:05.564
I don't need more than 6 inches.
01:02:05.564 --> 01:02:06.605
>> SANDRA WALIA: Okay.
01:02:06.605 --> 01:02:07.550
>> LAUREL DUVALL: So please don't
01:02:07.550 --> 01:02:09.781
send me a huge package of flooring. I
01:02:09.781 --> 01:02:11.888
don't want it. And I can't lift it
01:02:11.888 --> 01:02:14.992
anyways. [Laughter]
01:02:14.992 --> 01:02:15.846
>> SANDRA WALIA: Okay. The next
01:02:15.846 --> 01:02:18.550
one, what are the 3 types of assembled
01:02:18.550 --> 01:02:21.500
flooring panels?
01:02:21.500 --> 01:02:22.608
>> LAUREL DUVALL: What are the 3
01:02:22.608 --> 01:02:25.384
types of assembled flooring panels?
01:02:25.384 --> 01:02:26.347
>> SANDRA WALIA: Yes.
01:02:26.347 --> 01:02:27.071
>> LAUREL DUVALL: There are more
01:02:27.071 --> 01:02:29.980
than 3 types. There are all sorts of
01:02:29.980 --> 01:02:32.329
different kinds of assembled flooring
01:02:32.329 --> 01:02:33.558
panels. But for the ones we were
01:02:33.558 --> 01:02:35.821
talking about, there was, you know,
01:02:35.821 --> 01:02:39.160
there's the horizontal construction that
01:02:39.160 --> 01:02:41.438
has the strips side-by-side and in
01:02:41.438 --> 01:02:43.536
layers. There's the vertical
01:02:43.536 --> 01:02:46.788
construction where it's made of strips
01:02:46.788 --> 01:02:50.593
that are side-by-side. There's mosaic
01:02:50.593 --> 01:02:53.276
type flooring that it's made of specific
01:02:53.276 --> 01:02:56.125
pieces, you know, organized into a
01:02:56.125 --> 01:02:59.530
pattern. There's engineered flooring
01:02:59.530 --> 01:03:04.293
where it's multiple layers of wood,
01:03:04.293 --> 01:03:06.284
those are assembled. So you're looking
01:03:06.284 --> 01:03:08.945
for something with distinct pieces that
01:03:08.945 --> 01:03:11.214
are intentionally put together to form a
01:03:11.214 --> 01:03:13.835
whole.
01:03:13.835 --> 01:03:15.446
>> SANDRA WALIA: Okay. Then
01:03:15.446 --> 01:03:17.032
there's a few questions to go back to
01:03:17.032 --> 01:03:19.918
various slides, just to go back and look
01:03:19.918 --> 01:03:22.866
at it. One of them is slide 49 if you
01:03:22.866 --> 01:03:25.064
can go back to?
01:03:25.064 --> 01:03:26.256
>> LAUREL DUVALL: Okay. Let's do
01:03:26.256 --> 01:03:34.594
this. Okay. 49.
01:03:34.594 --> 01:03:36.543
>> SANDRA WALIA: Okay. And then
01:03:36.543 --> 01:03:39.675
there's a request for 51.
01:03:39.675 --> 01:03:40.305
>> LAUREL DUVALL: What was the
01:03:40.305 --> 01:03:41.852
question for 49?
01:03:41.852 --> 01:03:42.984
>> SANDRA WALIA: It was none. A
01:03:42.984 --> 01:03:45.476
lot of them are saying can you go back
01:03:45.476 --> 01:03:47.244
to the slide?
01:03:47.244 --> 01:03:47.878
>> LAUREL DUVALL: I see what you're
01:03:47.878 --> 01:03:50.594
saying. So here's 49. The next one is
01:03:50.594 --> 01:03:52.803
you said 51?
01:03:52.803 --> 01:03:55.397
>> SANDRA WALIA: Yeah. Let me get
01:03:55.397 --> 01:03:58.540
this out of the way.
01:03:58.540 --> 01:04:00.581
>> LAUREL DUVALL: Here's 51.
01:04:00.581 --> 01:04:04.375
>> SANDRA WALIA: Okay. Again, just
01:04:04.375 --> 01:04:17.866
to see it. Next one is 57. Okay. And
01:04:17.866 --> 01:04:31.650
then 26.
01:04:31.650 --> 01:04:34.254
>> While you're here, is veneer same
01:04:34.254 --> 01:04:35.793
as laminated?
01:04:35.793 --> 01:04:38.967
>> LAUREL DUVALL: No. Laminated
01:04:38.967 --> 01:04:45.918
means bonded. So lamination is bonding.
01:04:45.918 --> 01:04:48.375
With the term similar laminated wood,
01:04:48.375 --> 01:04:50.272
the explanatory notes tell us exactly
01:04:50.272 --> 01:04:52.878
what they mean by that kind of panel.
01:04:52.878 --> 01:04:56.419
So laminated is just an additive in
01:04:56.419 --> 01:05:03.819
that. But veneer is laminated on to a
01:05:03.819 --> 01:05:05.749
substrate. Meaning bonded to a
01:05:05.749 --> 01:05:08.052
substrate. Laminating does not mean
01:05:08.052 --> 01:05:11.047
veneer. Laminated mean it's pieces are
01:05:11.047 --> 01:05:15.062
bonded together. So for example, these
01:05:15.062 --> 01:05:23.665
vertical panels on slide 26, there's
01:05:23.665 --> 01:05:29.184
laminated together, it's not similar
01:05:29.184 --> 01:05:32.730
laminated wood of 4412. So laminated
01:05:32.730 --> 01:05:37.883
just means bonded.
01:05:37.883 --> 01:05:41.092
>> Just so I understand, face ply
01:05:41.092 --> 01:05:47.524
means top layer? Top layer, face ply,
01:05:47.524 --> 01:05:51.175
call it what you want to, but face ply
01:05:51.175 --> 01:05:53.340
is just my typical language and it
01:05:53.340 --> 01:06:00.286
happens to be a tariff term. You will
01:06:00.286 --> 01:06:02.262
find I language with a face apply of.
01:06:02.262 --> 01:06:06.766
So I refer to the top layer as face ply.
01:06:06.766 --> 01:06:09.038
>> And then there's just 4 more
01:06:09.038 --> 01:06:10.891
requests to go to the page numbers. One
01:06:10.891 --> 01:06:17.235
of them is Page 21.
01:06:17.235 --> 01:06:32.383
>> Okay. Page 21. And then 17.
01:06:32.383 --> 01:06:35.690
And then 15.
01:06:35.690 --> 01:06:40.784
>> Those are the nodes.
01:06:40.784 --> 01:06:45.716
>> And slide 11. Lats the last one
01:06:45.716 --> 01:06:47.715
I see.
01:06:47.715 --> 01:06:49.364
>> And I see one question that came
01:06:49.364 --> 01:06:54.340
in. Can small veneered shapes also fall
01:06:54.340 --> 01:07:01.666
under 4412 or does it have to be applied
01:07:01.666 --> 01:07:03.429
specifically?
01:07:03.429 --> 01:07:05.813
>> Small veneered applied shapes?
01:07:05.813 --> 01:07:07.309
I'm not sure what that means. But
01:07:07.309 --> 01:07:10.171
here's the thing. The term panel does
01:07:10.171 --> 01:07:15.167
not have, like, it does not have a
01:07:15.167 --> 01:07:20.741
definition that gives size limitations.
01:07:20.741 --> 01:07:23.962
So if I had a piece of plywood that was
01:07:23.962 --> 01:07:27.343
1 inch square, that's a panel. I mean,
01:07:27.343 --> 01:07:29.456
there's nothing that says a panel has to
01:07:29.456 --> 01:07:37.720
be a broad expanse. It's just basically
01:07:37.720 --> 01:07:39.749
flat and greater expanse than the
01:07:39.749 --> 01:07:42.569
thickness. But with plywood, lie wood
01:07:42.569 --> 01:07:46.635
is, you know, multilayer. So at least
01:07:46.635 --> 01:07:50.721
it's a flat piece that has 3 layers to
01:07:50.721 --> 01:07:52.983
it and the grain of each layer ones at
01:07:52.983 --> 01:07:59.378
an angle to the adjacent layers. So
01:07:59.378 --> 01:08:03.704
small piece of it, 1 by 1 inch. Or 4 by
01:08:03.704 --> 01:08:06.266
4 by 8 sheet, that's a panel. So don't
01:08:06.266 --> 01:08:09.899
get hung up on the word panel. Stick to
01:08:09.899 --> 01:08:13.138
the construction of it. So if you can
01:08:13.138 --> 01:08:14.910
see it's something made of layers and
01:08:14.910 --> 01:08:17.541
it's at least 3 layers, you know, and
01:08:17.541 --> 01:08:19.358
the grains run in different directions.
01:08:19.358 --> 01:08:21.269
Then you're looking at a piece of
01:08:21.269 --> 01:08:26.992
plywood.
01:08:26.992 --> 01:08:28.936
>> So the gentleman from before is
01:08:28.936 --> 01:08:32.778
asking, slide uses 3412, this greater
01:08:32.778 --> 01:08:38.823
than 5mm contradicts note 4b?
01:08:38.823 --> 01:08:40.204
>> Which slide was it?
01:08:40.204 --> 01:08:43.692
>> He said slide 35. Uses 4412.
01:08:43.692 --> 01:08:47.922
This greater than 5mm contradicts note
01:08:47.922 --> 01:08:48.685
4b.
01:08:48.685 --> 01:08:51.711
>> No, it doesn't conflict with note
01:08:51.711 --> 01:08:53.992
4b because it's not a flooring panel.
01:08:53.992 --> 01:08:58.796
Note 4b references assembled multilayer
01:08:58.796 --> 01:09:00.778
flooring panels. This is not a flooring
01:09:00.778 --> 01:09:05.339
panel. This is a non-descript,
01:09:05.339 --> 01:09:07.305
undedicated building material. Okay?
01:09:07.305 --> 01:09:09.866
It doesn't have the tongue and Grove.
01:09:09.866 --> 01:09:11.662
It doesn't have any joinery. It's not
01:09:11.662 --> 01:09:15.788
finished for uses for flooring. It's
01:09:15.788 --> 01:09:20.739
simply a building material. So this is
01:09:20.739 --> 01:09:23.203
not a recognizable article used in the
01:09:23.203 --> 01:09:25.843
construction of a building. Therefore,
01:09:25.843 --> 01:09:28.615
it cannot go into 4418. It is a
01:09:28.615 --> 01:09:33.715
veneered panel classified at
01:09:33.715 --> 01:09:33.938
4,412.10.9000.
01:09:33.938 --> 01:09:39.955
>> Okay. He said thank you. I see
01:09:39.955 --> 01:09:41.856
just one more slide request for slide
01:09:41.856 --> 01:09:48.272
12, if you can go back to that.
01:09:48.272 --> 01:09:58.089
>> Okay.
01:09:58.089 --> 01:09:59.591
>> Are that's it.
01:09:59.591 --> 01:10:00.757
>> Cool.
01:10:00.757 --> 01:10:02.230
>> You have note. Virtual checks
01:10:02.230 --> 01:10:05.657
for Laurel.
01:10:05.657 --> 01:10:06.612
>> LAUREL DUVALL: [Laughter] well,
01:10:06.612 --> 01:10:09.211
you know, if I had you guys here, I
01:10:09.211 --> 01:10:12.956
would be giving out woodchuck nickels.
01:10:12.956 --> 01:10:19.962
But I'm sorry it's virtual. Next time I
01:10:19.962 --> 01:10:22.968
see you I'll have wood Chuck nickels for
01:10:22.968 --> 01:10:25.003
all your good questions. Thank you so
01:10:25.003 --> 01:10:27.318
much. And I think that does bring us to
01:10:27.318 --> 01:10:33.056
the end here? I think that's maybe
01:10:33.056 --> 01:10:40.012
good? Yes? No? Maybe?
01:10:40.012 --> 01:10:41.188
>> CHRISSI GUTH: Yes.
01:10:41.188 --> 01:10:43.704
>> LAUREL DUVALL: Great. Great.
01:10:43.704 --> 01:10:45.293
Great. If you guys come up with any
01:10:45.293 --> 01:10:47.640
questions after we're done here, please
01:10:47.640 --> 01:10:49.874
just send me an email, and I will get
01:10:49.874 --> 01:10:55.344
back to you. Thanks!
01:10:55.344 --> 01:10:56.037
>> CHRISSI GUTH: This concludes our
01:10:56.037 --> 01:10:57.854
webinar for this afternoon. This is a
01:10:57.854 --> 01:11:00.003
reminder that this webinar will be
01:11:00.003 --> 01:11:02.329
posted on the CBP website. Thank you

01:11:04.166 --> 01:11:04.166
your day.