CLA-2-56:RR:NC:TA:350 D86003

Ms. Sally Cheng
Isolyser
4320 International Boulevard, NW
Norcross, GA 30093

RE: The tariff classification of PVA nonwoven cleaning wipes with alcohol, from China.

Dear Ms. Cheng:

In your letter dated December 7, 1998, which was received December 16, 1998, you requested a classification ruling.

Your letter indicated that you plan on importing nonwoven cleaning wipes impregnated with alcohol from China, Singapore or the Philippines. Submitted samples are of the material by itself and squares of the fabric impregnated with the alcohol.

You write that the nonwoven material, itself, is manufactured in China and that it is composed of polyvinyl alcohol man-made fibers with a weight of 30-35 grams per square meter. Information was not furnished, but it is believed that the fibers are of staple length. The impregnated material was informally weighed and found to be somewhat over 70 gr/mý.

It appears from your letter that the nonwoven material will be cut to a size of 16.25 by 16.75 inches, impregnated with alcohol, folded twice and packed 50-100 pieces in a plastic bag. Although the impregnated material has a different physical appearance ("spun lace" effect) than that of the pre treated material, this would not affect the classification of the goods. These wipes may be used in the automobile industry, cleaning rooms, pharmaceutical and/or airplane industries, etc.

From your letter we read that the material will all be manufactured in China, but the cutting to a rectangle and alcohol impregnation may also be performed in Singapore and the Philippines as well as China.

Noting, in such an operation as cutting and impregnation, it is the country where the fabric is produced that determines marking and susceptibility to quota and visa textile restraints and not additional non fabric forming processes performed in another country. The applicable subheading for the wipes will be 5603.93.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for nonwovens, whether or not impregnated, coated, covered or laminated, ... of other than filaments, weighing more than 70 g/mý but not more than 150 g/mý, impregnated, coated, or covered with material other than or in addition to rubber, plastics , wood pulp or glass fibers .... The duty rate will be 2.5 percent ad valorem. Effective January 1, 1999, the duty rate will be Free. .

This merchandise falls within textile category designation 223. Since the item is considered a product of China, a visa issued by China would be necessary regardless of where the product was cut and impregnated. The quota would likewise be charged against China.

The designated textile and apparel categories may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. Part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes. To obtain the most current information available, we suggest that you check, close to the time of shipment, the Status Report on Current Import Quotas (Restraint Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.

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,

Robert B. Swierupski
Director,
National Commodity
Specialist Division