CLA-2 CO:R:C:G 084794 JBW
Ms. Ruby L. Wood
Vice President
Evans and Wood & Co., Inc.
P. O. Box 610005
D/FW Airport, Texas 75261
RE: Classification of Auto Detail Towel
Dear Ms. Wood:
Your letter of May 11, 1989, on behalf of Win-Tex
Products, Inc., addressed to our district office in Dallas,
Texas, has been referred to this office for a binding ruling on
the classification of "auto detail" towels under the Harmonized
Tariff Schedule of the United States Annotated (HTSUSA).
FACTS:
The sample submitted for classification is a white
cotton cloth of low quality terry construction and with hemmed
edges. The article measures 38 by 40 centimeters. You state in
your letter that the intended use of merchandise is as a cleaning
cloth for auto detail shops, but that the cloth may be purchased
for other uses.
ISSUE:
What is the classification of cotton terry cloth used
principally as cleaning towels in auto detail shops?
LAW AND ANALYSIS:
The General Rules of Interpretation (GRI's) set forth
the legal framework in which merchandise is to be classified
under the HTSUSA. GRI 1 requires that classification be
determined first according to the terms of the headings of the
tariff and any relative section or chapter notes and, unless
otherwise required, according to the remaining GRI's taken in
order.
You state that the merchandise under consideration will
be used principally as cleaning towels for "auto detail" shops.
Generally, "auto detail" shops provide services for care of the
exterior and interior of automobiles and vans. These services
include washing and waxing the exterior, applying stripes or
decals, cleaning the engine, shampooing the carpeting, and
polishing the interior. The merchandise under consideration
would be used to apply and remove wax, shampoo, cleaners, or
other liquids or to be used as a cloth to remove dust or dirt.
Other uses of a towel of this size and construction would be as a
cleaning cloth to remove dirt or absorb liquids.
Heading 6307.10, HTSUSA, governs other made up
articles, including floorcloths, dishcloths, dusters, and similar
cleaning cloths. Note 7 to Section XI defines "made up" to mean,
inter alia, hemmed or with rolled edges. Therefore, the
merchandise under consideration falls under this heading, for it
is "made up," and its principal use is as a cleaning cloth.
Subheading 6307.10.1000 includes dustcloths, mop cloths, and
polishing cloths of cotton. The use of the merchandise is
principally for polishing, dusting, and mopping and is therefore
classified under this heading.
Heading 6307 also includes a breakout for shop towels.
The subheading specifies that shop towels are those towels
dedicated to use in garages, filling stations, and machine shops.
Shop towels are always of plain woven, non-pile construction, and
thus, the merchandise under consideration is not classifiable
under this subheading.
HOLDING:
The cotton terry cloth towel used for cleaning in "auto
detail" shops is classified under subheading 6307.10.1000,
HTSUSA, and falls within textile category 369.
Due to the changeable nature of the statistical
annotation (the ninth and tenth digits of the classification) and
the restraint (quota/visa) categories, you should contact your
local Customs office prior to importation of this merchandise to
determine the current status of any import restraints or
requirements.
Sincerely,
John Durant, Director
Commercial Rulings Division