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