CLA-2-56:RR:NC:TA:350 B83938
Ms. Katherine M. Pekovitch
A.V. Reilly International Ltd.
1555 North Michael Drive
Wood Dale, IL 60191
RE: The tariff classification of a "scrim felt" for use as
lettering, etc., on articles of apparel, from Italy.
Dear Ms. Pekovitch:
In your letter dated March 28, 1997, on behalf of All Felt
Products Inc., Genoa, IL, you requested a tariff classification
ruling. The manufacturer is Feltrifici Ruiniti International,
Italy.
The instant sample, as described in your letter, consists of
a needleloom felt composed of 100% polyester man-made fibers.
Specifically, it consists of polyester textile fibers that have
been needled through a base scrim. This felt has been sprayed with
a small amount of wheat starch which imbues the material with a
noticeable stiffness. This material is stated to weigh 300g/m2 and
is approximately .062" thick. After importation, this material
will be cut into various designs and then sewn or chenilled onto
clothing articles.
Your contention that this material is classifiable as a
nonwoven in subheading 5603.14.9090 is not correct. The principal
method of manufacture of this felt is needlepunching. Needled webs
of staple fibers or filament based webs in which the needling is
complimentary and not essential to the manufacture of the material
would mandate classification in heading 5603... Such is not the
case here.
The applicable subheading for the material will be
5602.10.9090, Harmonized Tariff Schedule of the United States
(HTS), which provides for felt, whether or not impregnated, coated,
covered or laminated, needleloom felt and stitch-bonded fiber
fabrics, ... of other than wool or fine animal hair. The rate of
duty will be 11.9 percent ad valorem.
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 George
Barth at 212-466-5884.
Sincerely,
Paul K. Schwartz
Chief, Textiles & Apparel Branch
National Commodity
Specialist Division