By Andy Wang     Photo：CANVA

If you want your cabinets to clear overseas customs smoothly, start with three basics: (1) confirm whether the product is in scope of any trade remedies or controls; (2) identify destination-market wood/chemical rules; and (3) make sure your documents are consistent and traceable. This guide lays out universal practices first, then highlights key differences for the U.S., EU, Japan/Korea, and major ASEAN supply bases—so you can reduce risk before you quote or place orders.

How to navigate
U.S. market → Section II.
EU → Section III.
Japan & Korea → Section IV.
ASEAN supply side → Section V.
Section VII contains copy-and-use “one-page data cards.” Section VIII is a search-style FAQ.

I. Universal principles (apply to any market)

1. Define the product with four elements.
   Materials & surface finish; finished set or knock-down parts; whether hardware is included; intended use & installation. If any of these are missing, classification and compliance will wobble.
2. Separate “scope” from “classification.”
   First determine whether the product falls within any trade-remedy or regulatory scope; only then assign the tariff classification. Industry nicknames don’t replace legal notes and headings.
3. Build a traceable evidence trail.
   BOM, supplier & subcontractor list, processing location & steps, proof of origin, images/drawings—each file should carry a date and version number.
4. Document consistency.
   Item names, materials, counts, and model numbers must match across invoice, packing list, labels, and your customs-declaration draft.
5. Work with your service partners.
   In most cases you interface with a freight forwarder, who coordinates with a customs broker for pre-classification and filing.
   If you already have a designated broker, they can pre-classify first; the forwarder then embeds the result into booking and clearance milestones.

II. United States essentials (trade remedies + wood rules in parallel)

1. Duties & remedies—current context
   After a five-year sunset review, the U.S. International Trade Commission (USITC) decided to maintain the AD/CVD orders on “Wooden Cabinets and Vanities and components thereof from China,” with the Federal Register (FR) notice published on Sept 9, 2025. The Department of Commerce (DOC) released preliminary results of the CVD administrative review in July 2025 and AD in August 2025 (period of review, POR: CVD 2023; AD 2023–2024). Names and rates will update upon the final results. In practice, quotes and contracts should follow the latest Federal Register notices, with a clause allowing adjustments to reflect final determinations.
2. Scope vs. classification—how to think about it
   Because the order title includes “and components thereof,” certain parts can be covered under specific conditions. Most wooden cabinets fall under Chapter 94 (9403-series) of the HTS, but the exact subheading still depends on legal notes and heading text. Let your customs broker do the final check.
3. Two “wood rules” you must align

Lacey Act declaration (APHIS). For covered lines, you must submit via ACE (Automated Commercial Environment) / LAWGS (Lacey Act Web Governance System) at import: botanical species (scientific name recommended), country of harvest, quantity/unit, and value. Phase VII expands coverage from Dec 2024.

TSCA Title VI formaldehyde (EPA). Composite wood panels (e.g., hardwood plywood, MDF, particleboard) and finished goods containing them must meet 40 CFR Part 770 requirements: emission limits, labeling, third-party certification, and recordkeeping. Labels commonly state “TSCA Title VI compliant,” and you should retain proof.

4. Anti-evasion risk (EAPA).
   Under the Enforce and Protect Act, CBP can act on transshipment, false origin, or minor processing. In May 2025, case 8137 on wooden cabinets/components initiated with interim measures—a clear signal to maintain robust origin evidence.
5. U.S. quick checklist (copy-ready)

• Ask your broker to pre-classify the HTS subheading.
• Lacey fields: species (scientific name) / harvest country / quantity + unit / value (broker files through ACE/LAWGS at import).
• If composite wood is used, retain TSCA Title VI labels and third-party certificates/test reports and keep records.
• Hand off pre-classification and “docs-complete” date to the forwarder to schedule booking and clearance.

III. European Union essentials (deforestation-free + REACH formaldehyde)

1. EUDR (deforestation-free).
   The EUDR requires due diligence with geolocation of plots, risk assessment, and risk mitigation for specified commodities and derived products. The EU shifted timelines at end-2024: medium/large operators from Dec 30, 2025; micro/small from Jun 30, 2026. Submit your Due Diligence Statement (DDS) through the EUDR Information System. Agree with your customer on who files the DDS, the coordinate format (point/polygon), and the file structure. Build an internal evidence flow from “source” to “goods received.”
2. REACH—formaldehyde restriction.
   New limits for formaldehyde and formaldehyde-releasers: 0.062 mg/m³ for furniture/wood products used indoors; 0.080 mg/m³ for most other products. Most provisions take effect Aug 6, 2026. If your cabinets include composite wood, prepare test reports or declarations of conformity, and ensure labeling language and documents are aligned.
3. What differs from the U.S.
   The U.S. emphasizes species/origin declaration and composite-wood emissions labeling (TSCA). The EU stresses deforestation-free due diligence and indoor emission limits (REACH). One product information set must satisfy both logics.
4. EU quick checklist (copy-ready)

• Due diligence essentials: source country, plot geolocation (point/polygon), risk assessment, risk mitigation.
• Evidence for REACH formaldehyde limits: test report or compliance statement.
• Labeling and instruction language must match the destination country.
• Confirm who files the DDS, when, and in what format.

IV. Japan & Korea essentials (legal timber and low-emission grades)

1. Japan—Clean Wood Act (amended).
   Effective Apr 1, 2025. Category-1 wood-related operators (larger/priority operators) must conduct legality confirmation, recordkeeping, information transfer, and—above threshold—periodic reporting. Guidance from the Forestry Agency and relevant ministries explains acceptable evidence. For exporters, set up supplier evidence chains and internal self-checks.
2. Japan—formaldehyde grade “F☆☆☆☆.”
   Under JIS/JAS, F☆☆☆☆ is the strictest (lowest-emission) grade commonly used for building materials and furniture. For first-time external communications: “F☆☆☆☆ (the lowest formaldehyde-emission grade under JIS/JAS; often rendered ‘Four-star’ in English).”
3. Korea—KS emission classes.
   KS defines formaldehyde emission classes (e.g., E1, E0, SE0). For indoor wood materials, E0 or stricter is commonly requested recently. Ask for KS certificates or equivalent reports during negotiations.
4. JP/KR quick checklist (copy-ready)

• Legal-timber paperwork and due-diligence procedure.
• Panel grades & test reports (F☆☆☆☆, E0, etc.).
• Local-language labeling and instructions.
• Customer audit/verification forms aligned in advance.

V. ASEAN supply-side (Vietnam, Indonesia, Malaysia)

1. Vietnam—VNTLAS.
   A risk-based timber legality assurance system; interfaces with FLEGT when exporting to the EU. Recent updates tighten risk orientation and procedural detail.
2. Indonesia—SVLK & FLEGT.
   National legality system; FLEGT licenses for EU exports have been in place since 2016. For the UK, FLEGT-licensed timber enjoys advantages under UKTR.
3. Malaysia—MTCS.
   The Malaysian Timber Certification Scheme is PEFC-endorsed and has been aligning with EUDR-style reporting. If your panels or logs originate in Malaysia, keep certificate numbers and validity for supply-chain audits.
4. Supply-side quick checklist (copy-ready)

• Supplier & subcontractor list, flagging key material sources.
• Evidence of processing location/steps; clarify if substantial transformation occurs.
• Certificates of origin and legality/chain-of-custody documents with clear numbers and validity dates.
• File naming and version control to prevent outdated samples from slipping in.

VI. Risk radar (3 red flags, 3 amber flags)

Red flags

1. Document vs. physical mismatch: invoice says “non-wood,” outer carton says “wood”; model counts don’t match.
2. Origin narrative not self-consistent: origin claims a third country but can’t prove material source or substantial transformation—a prime EAPA concern.
3. Wood rules ignored: missing Lacey data or TSCA Title VI labeling/declarations.

Amber flags

1. Insufficient knock-down detail: only “door panel/side panel,” with no material, finish, pre-drilling, or hardware status.
2. Loose sample/version control: label mockups, invoice wording, and e-entry differ; files lack dates and version numbers.
3. Over-reliance on trade nicknames: classification must follow legal notes and heading text; always let the broker do the final ruling.

VII. One-page data cards (two templates—copy and use)

A. For U.S. exports

1. Product name & model.
2. Materials & finish: solid wood, plywood, MDF, etc. (Supplier/Factory)
3. Finished set or knock-down; pre-drilled or veneered; hardware included? (Factory)
4. Intended use & installation: kitchen or bath; wall-mounted or floor-standing (Factory/Brand)
5. Proposed HTS subheading—pre-classify with your customs broker (Broker)
6. Lacey Act fields (Factory/Supplier): species (scientific name) / harvest country / quantity + unit / value (Broker files via ACE/LAWGS at import)
7. TSCA Title VI: label mockups and third-party certification/test reports (as applicable; Panel Supplier/Factory), plus recordkeeping (Factory/Brand)
8. Cross-check consistency: invoice, packing list, labels, entry draft (Brand/Factory/Broker jointly)

B. For EU exports

1. Same core description as above, plus labeling language (Brand)
2. EUDR minimum due-diligence set (Factory/Supplier → Brand): source country, plot geolocation (point/polygon), risk assessment, risk mitigation
3. DDS submission flow: who submits (Brand or Buyer); channel: EUDR Information System; agreed file formats
4. REACH formaldehyde: test report or declaration (Panel Supplier/Factory → Brand)
5. File consistency & version control aligned to the customer’s submission format (Brand)

VIII. Search-style FAQ

1. When does EUDR apply to furniture?
   Dec 30, 2025 for medium/large operators; Jun 30, 2026 for micro/small—subject to the latest EU notices. DDS is filed via the EUDR Information System.
2. What are the REACH indoor formaldehyde limits for furniture?
   0.062 mg/m³ for furniture/wood products; 0.080 mg/m³ for most other products. Most provisions apply from Aug 6, 2026.
3. What must be declared under the U.S. Lacey Act?
   Species (scientific name) / harvest country / quantity + unit / value, depending on the line list and timeline; filed in ACE/LAWGS at import.
4. What is TSCA Title VI?
   EPA’s emission and labeling rule for composite wood panels and finished goods containing them, including labeling, third-party certification, and recordkeeping.
5. What is EAPA?
   CBP’s anti-evasion mechanism. In May 2025, cabinet case 8137 showed how interim measures may be applied.
6. What changed in Japan’s Clean Wood in 2025?
   Effective Apr 1, 2025; Category-1 operators have mandatory legality checks, recordkeeping, information transfer, and (above threshold) reporting.
7. KS E0 vs. E1 in Korea?
   Different formaldehyde-emission limits and test methods; E0 or stricter is commonly requested for indoor use (exact limits depend on the KS item/method).

IX. Key takeaways & next steps

Define first, swap rules second, schedule last. Write down materials & finish, finished vs. knock-down, hardware status, intended use & installation—then bundle BOM, source and processing proof into a one-page data card. Get your broker to pre-classify; let your forwarder embed the results into booking and clearance milestones. When in doubt, follow official notices and legal text first, then confirm execution with your service providers.

Glossary (quick reference)

USITC: U.S. International Trade Commission
DOC/Commerce: U.S. Department of Commerce
CBP: U.S. Customs and Border Protection
AD/CVD: Anti-Dumping / Countervailing Duty
Lacey Act: U.S. legality declaration for timber and plant products (administered by APHIS)
TSCA Title VI: U.S. composite-wood formaldehyde emissions & labeling rule (administered by EPA)
EAPA: Enforce and Protect Act—CBP’s anti-evasion framework
EUDR: EU Deforestation-free Regulation
REACH: EU chemical regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals)
JIS/JAS: Japanese Industrial Standards / Japanese Agricultural Standards
F☆☆☆☆: Lowest formaldehyde-emission grade under JIS/JAS (“Four-star”)
KS: Korean Industrial Standards; common emission classes E1/E0/SE0
VNTLAS / SVLK / MTCS: Timber-legality/certification systems in Vietnam, Indonesia, Malaysia; PEFC is an international endorsing body

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