The US Department of Commerce's final determinations in the hardwood plywood investigations cover 35 HTS codes under heading 4412, with antidumping duties ranging from 0.00% to 194.90% and countervailing duties from 0.00% to 35.48% depending on the source country and exporter.
Scope of Covered HTS Codes
The investigations target hardwood and decorative plywood classified under HTS heading 4412, spanning subheadings 4412.10 through 4412.99. The complete list includes bamboo plywood (4412.10.0500), tropical hardwood plywood with face plies of certain species (4412.31 series), and softwood-faced panels with hardwood cores (4412.33 and 4412.34 series). The following subheadings appear in the final scope determination:
- 4412.10.0500 (bamboo plywood)
- 4412.31.0520, 4412.31.0540, 4412.31.0560, 4412.31.0620, 4412.31.0640, 4412.31.0660
- 4412.31.2510, 4412.31.2520, 4412.31.2610, 4412.31.2620
- 4412.31.4040, 4412.31.4050, 4412.31.4060, 4412.31.4070, 4412.31.4080
- 4412.31.5125, 4412.31.5135, 4412.31.5155, 4412.31.5165
- 4412.31.6000, 4412.31.9100
- 4412.33.0610, 4412.33.0630, 4412.33.3000, 4412.33.5110, 4412.33.5130
- 4412.34.2410, 4412.34.2430, 4412.34.3110, 4412.34.3130, 4412.34.3155, 4412.34.3165
- 4412.94.1030, 4412.94.1050
- 4412.99.5710, 4412.99.5730
Final Duty Rates by Country
Commerce published final AD/CVD determinations in December 2017 for China and issued subsequent determinations for Indonesia and Vietnam. The China-specific rates established mandatory respondent margins: Linyi Chengen Import and Export Co. received a combined AD rate of 183.36%, while other Chinese exporters face the all-others rate of 194.90% AD plus 22.98% to 35.48% CVD depending on the specific company.
Indonesian exporters are subject to AD rates between 4.31% and 61.94%, with CVD rates from 0.00% to 5.03%. Vietnamese producers face AD margins ranging from 0.00% (for PT. Kutai Timber Indonesia) to 183.36%, depending on their individual review status. The ITC issued affirmative injury determinations for all three countries, making these orders effective.
Classification Edge Cases and System Implications
The scope language creates classification complexity that static HTS lookups cannot resolve. Plywood with face and back veneers of different species may qualify under multiple 10-digit codes. Products with face veneers exactly 6mm thick occupy a boundary condition—above this threshold, certain exclusions apply. Panels with fire-retardant treatment or pressure-treated preservatives remain in scope despite their specialized use cases.
For API consumers, this means caching HTS duty rates without the AD/CVD layer produces incomplete landed cost calculations. The effective rate for 4412.31.4040 varies by country of origin, specific exporter, and whether the product meets the physical scope criteria. Systems must query both the base HTS rate and the applicable trade remedy case number (A-570-051 for China AD, C-570-052 for China CVD, and corresponding case numbers for Indonesia and Vietnam).
Practical Integration Considerations
Compliance systems pulling HTS data should flag all 4412.XX.XXXX codes when the country of origin is CN, ID, or VN. Commerce periodically conducts administrative reviews that modify company-specific rates—the most recent China review (2022-2023) adjusted rates for 17 individual exporters. These rate changes typically publish 12-18 months after the review period closes, requiring continuous monitoring rather than annual updates.
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