Commerce Initiates AD and CVD Investigations on Wooden Cabinets
and Vanities from China

March 29, 2019

In CSMS # 19-000166, March 29, 2019, CBP announced that Commerce initiated Antidumping and countervailing duty investigations on “Wooden Cabinets and Vanities and Components Thereof from the People’s Republic of China (China)”. These investigations were assigned case numbers A-570-106 and C-570-107.

Scope of the Investigations

The scope of merchandise covered by these investigations is described as:

Wooden cabinets and vanities that are for permanent installation (including floor mounted, wall mounted, ceiling hung or by attachment of plumbing), and wooden components thereof.

Wooden component parts of cabinets and vanities, such as:

(1) wooden cabinet and vanity frames,
(2) wooden cabinet and vanity boxes (which typically include a top, bottom, sides, back, base blockers, ends/end panels, stretcher rails, toe kicks, and/or shelves),
(3) wooden cabinet or vanity doors,
(4) wooden cabinet or vanity drawers and drawer components (which typically include sides, backs, bottoms, and faces),
(5) back panels and end panels,
(6) and desks, shelves, and tables that are attached to or incorporated in the subject merchandise.

Wooden cabinets and vanities are covered by the investigation whether or not they are imported attached to, or in conjunction with, faucets, metal plumbing, sinks and/or sink bowls, or countertops. If wooden cabinets or vanities are imported attached to, or in conjunction with, such merchandise, only the wooden cabinet or vanity is covered by the scope.

Wooden cabinets and vanities and wooden components are made substantially of wood products, including solid wood and engineered wood products (including those made from wood particles, fibers, or other wooden materials such as plywood, strand board, block board, particle board, or fiberboard), or bamboo. Wooden cabinets and vanities consist of a cabinet box (which typically includes a top, bottom, sides, back, base blockers, ends/end panels, stretcher rails, toe kicks, and/or shelves) and may or may not include a frame, door, drawers and/or shelves.

The scope of investigation includes wooden cabinets and vanities with or without wood veneers, wood, paper or other overlays, or laminates, with or without non-wood components or trim such as metal, marble, glass, plastic, or other resins, whether or not surface finished or unfinished, and whether or not completed.

“Ready to Assemble” (RTA) Wooden Cabinets and Vanities

The wooden cabinets and vanities unassembled, assembled and/or “ready to assemble” (RTA) wooden cabinets and vanities, also commonly known as “flat packs,” unless the merchandise is already covered by the scope of antidumping and countervailing duty orders on Hardwood Plywood from the People's Republic of China. 

RTA wooden cabinets and vanities are defined as cabinets or vanities packaged so that at the time of importation they may include:

(1)   wooden components required to assemble a cabinet or vanity (including drawer faces and doors); and
(2)   parts (e.g., screws, washers, dowels, nails, handles, knobs, adhesive glues) required to assemble a cabinet or vanity.

RTAs may enter the United States in one or in multiple packages.

Wooden Cabinets, Vanities and Components
Further Processed in a Third Country

The scope of investigation also includes wooden cabinets and vanities and in-scope components that have been further processed in a third country, including but not limited to one or more of the following:

trimming, cutting, notching, punching, drilling, painting, staining, finishing, assembly, or any other processing that would not otherwise remove the merchandise from the scope of the investigation if performed in the country of manufacture of the in-scope product.

Targeting Tariff Classifications

Wooden cabinets and vanities subject to the Orders may be classified under HTSUS 9403.40.9060 and 9403.60.8081.

Component parts of the subject wooden cabinets and vanities may be entered under HTSUS 9403.90.7080. These classifications are provided for convenience and customs purposes. The written description of the scope of these investigations is dispositive.

Products That Are Excluded

Excluded from the investigation are the following as long as the items are entered separately from a wooden cabinet or vanity:

  1. Aftermarket accessory items which may be added to or installed into an interior of a cabinet and which are not considered a structural or core component of the wooden cabinet or vanity. Aftermarket accessories may be made of wood, metal, plastic, composite material or a combination thereof that can be inserted in a cabinet and which function in the organization/accessibility of the interior of a cabinet. Aftermarket accessory items include:

    • Inserts or dividers placed into drawer boxes for organizing or dividing the internal portion of the drawer into multiple areas for the purpose of containing smaller items such as cutlery, utensils, bathroom essentials, etc.
    • Round or oblong inserts that rotate internally in a cabinet for the purpose of accessibility to foodstuffs, dishware, general supplies, etc.
  1. Solid wooden accessories including corbels and rosettes that serve the primary purpose of decoration and personalization.

  2. Non-wooden cabinet hardware components including metal hinges, brackets, catches, locks, drawer slides, fasteners (nails, screws, tacks, staples), handles, and knobs.

Also excluded from the investigations are:

  1. All products covered by the scope of the antidumping duty order on Wooden Bedroom Furniture from the PRC. See Notice of Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order: Wooden Bedroom Furniture from the People’s Republic of China, 70 FR 329 (January 4, 2005).

  2. Products covered by the scope of the antidumping and countervailing duty orders on Hardwood Plywood from the People's Republic of China. See Certain Hardwood Plywood Products from the People’s Republic of China: Amended Final Determination of Sales at Less Than Fair Value, and Antidumping Duty Order, 83 FR 504 (January 4, 2018); Certain Hardwood Plywood Products from the People’s Republic of China: Countervailing Duty Order, 83 FR. 513 (January 4, 2018).

Invitation for Comments on the Scope of the Investigations

Interested parties may raise issues regarding the scope of the investigation. The comment period is intended to provide Commerce opportunity to consider all comments and to consult with parties prior to the issuance of the preliminary determinations.

All initial comments must be submitted by 5:00 pm Eastern Time (ET), April 15, 2019 (20 calendar days from the signature date of the notice of these investigations. Rebuttal comments, which may include factual information, must be filed by 5:00 pm ET on April 25, 2019 (10 calendar days after the initial comments deadline).

For further information or questions about this or other customs issues, please contact George Tuttle, III, at or 415-986-8780.

George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle in the San Francisco Bay Area.

The information in this article is general in nature, and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.

Copyright © 2019 by Tuttle Law Offices.  

All rights reserved.  Information has been obtained from sources believed to be reliable.  However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.


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