CLA-2-:S:N:N3H:350 877599
Mr. Rudy A. Pina
R.A. Pina & Associates, Inc.
P.O. Box 2496
Nogales, AZ 85628
RE: The tariff classification of cotton swabs for general
hygiene use, from Mexico.
Dear Mr. Pina:
In your letter dated August 14, 1992, on behalf of Labor
International, you requested a tariff classification ruling.
You state in your correspondence that these swabs begin their
manufacture with polypropylene pellets of U.S. origin that are
sent to Mexico where they undergo an extrusion process. The
pellets are extruded into long polypropylene sticks which are
referred to as "straws". Once these polypropylene straws have
cooled, they are cut to lengths of 73mm and from that point on
are referred to as "sticks". After these sticks are cut to
length, the ends of the sticks are wrapped with cotton. This
cotton, which is of U.S. origin, is first carded in the U.S. with
the resulting sliver coiled by a continuous circular motion. The
cotton is then bagged and placed into shipping cartons of
approximately 17 pounds each before being sent to Mexico. The
finished swabs in Mexico are finally dried and put up in blister
packs for their ultimate sale.
While you mention the word assembly in your letter, no
allowance in duty can be made for the U.S. supplied components
due to the extensive manufacturing operations that were performed
on the raw materials in Mexico.
The applicable subheading for the swabs, therefore, will
be 5601.21.0090, Harmonized Tariff Schedule of the United States
(HTS), which provides for articles of cotton wadding. The rate
of duty will be 7.2 percent ad valorem.
While these swabs fall within textile category designation
369, they are not subject to either quota or the requirement of a
visa at the present time.
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