CLA-2-48:OT:RR:NC:4:434
Mr. George Keller
CASI Customs Consultants
100 Hartsfield Centre Parkway Suite 350
Atlanta, GA 30354
RE: The tariff classification of non-woven paper in rolls from China
Dear Mr. Keller:
In your letter dated April 13, 2017, you requested a tariff classification ruling on behalf of your client, Berkshire Corporation. Samples were submitted for our review and were sent for CBP laboratory analysis. We regret any inconvenience the delay may have caused. Lab report NY20170627 was issued August 30, 2017. In this case the composition of the paper provided in your ruling request differed from the lab results. We will rely on the lab conclusions for the purposes of this ruling.
Products RMECW305036 and RMECW305045 are both rolls of composite non-woven paper which, per CBP lab analysis, are composed of 53% cellulosic wood pulp fibers and 47% man-made staple fibers. The non-woven paper is manufactured using hydro-entanglement. The rolls will be imported in widths of 91 cm and 114 cm respectively. Each roll is 2000 – 3000 meters in length. The paper stock will be further manufactured into cleaning wipes in the United States.
Products RMECW305636 and RMECW305645 are both rolls of composite non-woven paper which, per CBP lab analysis, are composed of 50.6% cellulosic wood pulp fibers and 49.4% man-made staple fibers. The non-woven paper is manufactured using hydro-entanglement. The rolls will be imported in widths of 91 cm and 114 cm respectively. Each roll is 2000 – 3000 meters in length. The paper stock will be further manufactured into cleaning wipes in the United States.
The Explanatory Notes provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. The Explanatory Notes to Chapter 48 state that, “Paper consists essentially of the cellulosic fibres of the pulps of Chapter 47 (pulp of wood) felted together in sheet form. Many products, such as certain tea bag materials, consist of a mixture of these cellulosic fibres and of textile fibres (in particular man-made fibres as defined in Note 1 to Chapter 54). Where the textile fibres predominate by weight, the products are not regarded as paper…” In the instant case the cellulosic wood fibers do predominate by weight, and therefore the products are considered paper.
The applicable subheading for the paper rolls will be 4803.00.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Toilet or facial tissue stock, towel or napkin stock and similar paper of a kind used for household or sanitary purposes, cellulose wadding and webs of cellulose fibers, whether or not creped, crinkled, embossed, perforated, surface-colored, surface decorated or printed, in rolls or sheets: Other. The rate of duty will be free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported.
If you have any questions regarding the ruling, contact National Import Specialist Charlene Miller at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division