CLA-2-52:S:N:N6:352 807493
Mr. Les Etters
Etters International
2077 Airport Drive
Green Bay, Wisconsin 54313
RE: The tariff classification of plain woven 100% cotton cloths
impregnated with water, emulsifiers, preserving agents,
medicinal agents and/or perfumery products and individually
packed in plastic coated aluminum foil pouches. These
products will be produced in Germany.
Dear Mr. Etters:
In your letter dated February 27, 1995 you requested a
tariff classification ruling.
Five samples designated as "Re-vitalizer", "Muscle Power",
"Antiperspirant", "Coolmed" and "Dental" accompanied your request
for a ruling. Each of the products are 100% cotton bleached
plain woven fabric cut to rectangular shape and impregnated with
several fluids and packed in individual plastic coated aluminum
foil pouches. The fabric cloths are identical in construction
and vary only in the type and combination of ingredients with
which they have been impregnated. The fabric contains 13 single
yarns per centimeter in the warp and 16 single yarns per
centimeter in the filling. Weighing 130 g/m2, these products
will measure approximately 20 centimeters by 19 centimeters.
Based on the data provided the average yarn number for this
fabric has been calculated to be 22 in the metric system.
The sample identified as "Re-vitalizer" has been saturated
with a solution consisting an emulsifier, a perfume compound,
several preserving agents and demineralized water. The perfume
compound is in turn a mixture of concretes, essential oils,
residues and distillates of the eucalyptus plant. It will
function to cleanse and refresh the user in a variety of
situations where access to soap and running water is not an
available option. The sample identified as "Coolmed" has been
treated with an emulsifier, several preserving agents, herbal
extracts and demineralized water. It will be used in a manner
similar to the "Re-vitalizer".
The "Antiperspirant" cloth has been impregnated with an
emulsifier, a perfume compound, herb extracts, several preserving
agents, the antiperspirant aluminum hydrochloride and
demineralized water. This product will be used as an
antiperspirant.
The product designated as "Muscle Power" is saturated with
camphor, menthol, ethanol, allantoin, the essential oil pine oil
and demineralized water. It is unclear how or under what
circumstances this product is used. The final item is designated
as "Dental". A list of the ingredients in the saturating fluid
for this product was not provided. The packaging information
indicates that this item will be refrigerated and applied
externally to the body to treat strains or as a compress after
dental treatment.
The applicable subheading for the two products designated as
"Re-vitalizer" and "Coolmed" will be 5208.22.4090, Harmonized
Tariff Schedule of the United States (HTS), which provides for
woven fabrics of cotton, containing 85 percent or more by weight
of cotton, weighing not more than 200 g/m2 bleached, plain weave,
weighing more than 100 g/m2, of number 42 or lower number,
cheesecloth. The rate of duty will be 8.4 percent ad valorem.
The applicable subheading for the product designated as
"Antiperspirant" will be 3307.20.0000, HTS, which provides for
personal deodorants and antiperspirants. The rate of duty will
be 4.9 percent ad valorem.
You have not provided sufficient information for us to issue
a ruling on the products designated as "Dental" and "Muscle
Power". In order for a ruling to be issued on these items, you
must submit a complete list detailing the chemical name of each
ingredient in the saturating fluid as well as the function of
each ingredient in the overall use of the product. In addition,
detail how and for what purpose these two products are used.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport