HS 4412.39 Canadian Plywood Under Section 338: Worked Duty Stack by Thickness, Veneer Grade, and Softwood vs Tropical

Section 338 duties on covered Canadian-origin plywood take effect at 12:01 AM EDT on August 19 2026. HTS 4412.39 is the residual heading for plywood with non-coniferous, non-tropical face veneers, which captures most Canadian birch, maple, oak, poplar, and mixed hardwood plywood shipments. This is a walkthrough of the duty math by thickness and face veneer for the eight days before the cliff.

What HTS 4412.39 Covers

HTS 4412.39 covers plywood, veneered panels, and similar laminated wood with each ply not exceeding 6 mm in thickness, with at least one outer ply of non-coniferous wood, other than tropical wood specified in subheading note 2 to Chapter 44.

The Chapter 44 tropical species list includes meranti, lauan, keruing, mahogany, and other Southeast Asian and African tropical hardwoods. Canadian face veneer plywood is not on that list because Canadian mills do not produce tropical face veneers.

The 10-digit statistical breakdown further separates by end-use application, thickness, and face treatment:

• 4412.39.1020: plywood with at least one outer ply of birch
• 4412.39.1050: plywood with at least one outer ply of certain hardwoods, other
• 4412.39.4030: other plywood other, with each ply not exceeding 6mm
• 4412.39.5030: other plywood, sanded

For Canadian shipments, the most common statistical suffixes are 4412.39.1020 (birch face, from Quebec and Ontario mills) and 4412.39.1050 (maple, oak, or mixed hardwood face).

Pre-August 19 Baseline

USMCA qualifying Canadian-origin 4412.39 plywood clears at 0 percent MFN. USMCA qualification requires:

• Production in Canada, Mexico, or the United States.
• Meeting the specific rule of origin for Chapter 44 which for 4412.39 requires either a change to Chapter 44 from any other chapter, or a change from any other heading, whichever applies to the specific end-product.
• Cert paperwork on file with the importer, ready for CBP verification if requested.

Non-USMCA qualifying (which happens when production process breaks the rule of origin, or when cert paperwork is not maintained) clears at 8 percent MFN Column 1.

Post-August 19 Section 338 Layer

HTS 4412.39 is on Annex II of Proclamation 11062 covering Canadian wood products. The 50 percent Section 338 duty stacks over the base rate regardless of USMCA qualification.

• USMCA qualifying 4412.39: 0 percent MFN plus 50 percent Section 338 equals 50 percent effective rate.
• Non-USMCA qualifying 4412.39: 8 percent MFN plus 50 percent Section 338 equals 58 percent effective rate.

USMCA cert paperwork does not waive Section 338. This is analogous to how Section 232 and Section 301 duties stack over USMCA on covered goods.

Worked Landed Cost: 40-Foot Container of 18mm Birch Plywood

A 40-foot container typically holds 800 to 1,000 sheets of 18mm x 4x8 birch plywood at approximately 20 tons cargo weight. Assume 200k CIF Quebec-to-New-York entry, HTS 4412.39.1020 with USMCA cert:

Pre-August 19 2026:

• 0 percent USMCA MFN duty
• MPF 0.3464 percent capped at 634.62
• HMF 0.125 percent on port cargo, 250 approximate
• Total duty approximately 885
• Landed cost 200,885

Post-August 19 2026:

• 0 percent USMCA MFN
• 50 percent Section 338 layer equals 100,000 duty
• MPF capped 634.62
• HMF 250
• Total duty approximately 100,885
• Landed cost 300,885

Same sheet count now costs 100k more. Per-sheet cost jumps roughly 100 to 125 dollars depending on the exact sheet count in the container.

Worked Landed Cost: 40-Foot Container of 12mm Birch Plywood

A 40-foot container typically holds 1,200 to 1,500 sheets of 12mm x 4x8 birch plywood. Same 200k CIF budget.

Section 338 duty scales with CIF value not sheet count. Both 12mm and 18mm shipments at the same 200k CIF face the same 100,000 Section 338 layer. Per-sheet duty impact is lower on 12mm (about 65 to 85 dollars per sheet) versus higher on 18mm (about 100 to 125 dollars per sheet).

Importers who can substitute thinner sheets for the same application (cabinet-back and drawer-bottom uses) see slightly better per-sheet economics but the total duty exposure is the same.

Softwood Plywood: HTS 4412.94 and 4412.99

Softwood construction-grade plywood is not under 4412.39. It falls under:

• HTS 4412.94: plywood with at least one outer ply of coniferous wood, other than as specified above, with each ply not exceeding 6mm (spruce-pine-fir face).
• HTS 4412.99: other plywood with coniferous face.

Both 4412.94 and 4412.99 are on Annex II of Proclamation 11062. Same 50 percent Section 338 layer applies. Pre-August 19 USMCA baseline is 0 percent for 4412.94, non-USMCA is 8 percent. Post-August 19: 50 percent USMCA, 58 percent non-USMCA.

Softwood plywood volumes are much higher than hardwood plywood in the US-Canada trade lane. Aggregate Section 338 impact is largest on 4412.94 despite the per-unit value being lower than birch or maple hardwood plywood.

Substantial Transformation Traps

An importer routing hardwood plywood through Vietnam or Cambodia to avoid Chinese ADD/CVD, who is now considering routing through Canada to avoid Section 338, needs a full substantial transformation analysis on both origin claims.

For Canadian-origin analysis, CBP looks at where the plywood was actually manufactured (glued, pressed, sanded, sized). Canadian mills doing full production from Canadian veneer meet the origin test cleanly. Canadian mills that import Chinese veneer, glue it in Canada, and export as Canadian-origin face substantial transformation scrutiny under 19 CFR 134.35. The Canadian glue-and-press operation typically does not effect substantial transformation on plywood; the origin flips back to the veneer country of origin.

Chapter 99 Line-Item Coding Post-August 19

Entry summary line 30 for HTS 4412.39 plywood post-August 19 2026 requires an additional Chapter 99 line item for Section 338. The specific heading number will be assigned in the pending CBP CSMS.

Based on the Section 122 rollout pattern (Chapter 99 heading 9903.03.01), the Section 338 heading will likely fall in the 9903.75.XX or 9903.76.XX range.

Filers should default to a placeholder heading pending CSMS assignment and file a Post Summary Correction under 19 CFR 141.111 once the operative heading is assigned. Chapter 99 line-item transparency matters because per-heading provenance is required for PSC (19 USC 1520), drawback (19 USC 1313(j)), and reconciliation filings. Blended-duty coding breaks these downstream refund pathways.

What to Do This Week

For plywood importers with Canadian-origin 4412.39 (or 4412.94, 4412.99) inventory in FTZ or bonded warehouse position, Privileged Foreign election on Form 214 under 19 CFR 146.41(e) locks in the pre-August 19 rate on withdrawal.

For plywood on the water arriving between August 15 and August 25, coordinate with the customs broker to file entry summary before the August 19 12:01 AM EDT instant where physically possible. Water-time cannot be used to shelter covered goods; the pin is date of entry under 19 CFR 141.68.

For plywood already delivered pre-August 19 and cleared into US customs territory, no Section 338 exposure on that specific shipment. Section 338 attaches at entry.

For new orders being placed now for arrival post-August 19, rebuild the landed cost model with the 50 percent Section 338 layer and revisit sourcing decisions. Softwood plywood from US mills (Georgia-Pacific, Weyerhaeuser, Boise Cascade) may be competitive on a landed basis for the first time in years. Hardwood plywood from Vietnam or Malaysia may be competitive on price but comes with substantial transformation scrutiny given the volume of Chinese veneer routing through Southeast Asia.