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HQ 083446

February 23, 1990

CLA-2 CO:R:C:G 083446 CC


TARIFF NO.: 6302.91.0045; 6307.10.2005

Mr. Ralph H. Sheppard
Adduci, Mastriani, Meeks & Schill
551 Fifth Avenue
New York, N.Y. 10176

RE: Classification of towels

Dear Sir:

This letter is in response to your inquiry of November 16, 1988, on behalf of Win-Tex Products, Inc., requesting tariff classification of towels from China under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). Samples were submitted for examination.


The samples, consisting of three towels, are designated by you as styles 1531, 1532, and 1533. Styles 1531 and 1533 are bleached white. Style 1531 measures approximately 24 inches by 36 inches; Style 1533 measures approximately 36 inches by 36 inches. Style 1532, which measures 24 inches by 36 inches, has a print representing cows, horses, pigs, flowers, trees, a house, and the expression "Good Morning!"

All of the towels are made of the same coarse 100 percent cotton woven fabric. Also, they are all hemmed on two sides and have a selvedge edge on two sides.


Whether the submitted samples are classifiable as kitchen towels in Heading 6302, HTSUSA, or as shop towels in Heading 6307, HTSUSA?


Classification of merchandise under the HTSUSA is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes.

Heading 6302, HTSUSA, provides for kitchen linen, among other articles. The Explanatory Notes, the official interpretation of the HTSUSA at the international level, state for Heading 6302 that kitchen linen includes articles such as tea towels and glass cloths. Articles such as floor cloths, dish cloths, scouring cloths, dusters and similar cleaning cloths, generally made of coarse, thick material, are not regarded as falling within the description "kitchen linen" and are excluded from Heading 6302; instead, such items are classifiable in Heading 6307, HTSUSA.

You state that each of the submitted towels satisfies the criteria for dish towels according to the Guidelines for the Reporting of Imported Products in Various Textile and Apparel Categories, CIE 13/88, November 23, 1988. They state, at page 2, concerning dish towels:

With one exception, dish towels always have a design printed on them or woven or knit into them. The design may be in the form of pictures of fruit, kitchen utensils, chickens, etc., or may be checks, stripes, or similar patterns. The dish towels that usually do not have a design are light weight, plain woven, nonpile cotton towels that may be similar to, but readily distinguishable from, shop towels which are made from a much coarser fabric.

We would agree that the print on the submitted sample designated as Style 1532 distinguishes this towel as a dish towel, based on the Textile Guidelines. Therefore, this submitted sample is classifiable in Heading 6302, HTSUSA.

We do not believe that Styles 1531 and 1533, which do not contain a print, are distinguishable from shop towels. They are made of a coarse fabric typical of shop towels. Therefore, Styles 1531 and 1533 are classifiable in Heading 6307, HTSUSA, as shop towels.


Styles 1531 and 1533 are classified under subheading 6307.10.2005, HTSUSA, as other made up articles, floorcloths, dishcloths, dusters and similar cleaning cloths, other, shop towels, of cotton. The rate of duty is 10.5 percent ad valorem and the textile category is 369.

The sample designated as Style 1532 is classified under subheading 6302.91.0045, HTSUSA, which provides for bed linen, table linen, toilet linen and kitchen linen, other, of cotton, other, towels, other, dish. The rate of duty is 10.5 percent ad valorem and the textile category is 369.

Due to the changeable nature of the statistical annotation (the ninth and tenth digits of the classification) and the restraint (quota/visa) categories applicable to textile merchandise, you should contact your local Customs office prior to importation of this merchandise to determine the current status of any import restraints or requirements.

The designated textile and apparel category may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. Since 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.


John Durant, Director

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