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HQ 086132

February 22, 1990

CLA-2 CO:R:C:G 086132 CMR


TARIFF NO.: 6307.90.9010

T. Porter Clary
Commercial Attache
American Embassy
Tegucigalpa, D.C., Honduras, C.A.

RE: Request, on behalf of Wong Yu Yung, for binding ruling on surgical towels from Honduras

Dear Mr. Clary:

This ruling is in response to your letter on behalf of Mr. Wong Yu Yung of Cinkong International Co. Ltd. regarding the classifi- cation of surgical towels which will be imported from Honduras.


One hundred percent cotton woven fabric is imported in rolls from Hong Kong. The fabric will be cut, washed, seamed, folded and packaged as towels in Honduras. The towels will be exported to the United States where they will be sanitized and sterilized for final use. The principal use is for hospitals and clinics as surgical towels. Two samples have been submitted.


Are the processes which will be performed in Honduras sufficient to change the country of origin of the subject towels from Hong Kong, where the fabric originates, to Honduras?


For a textile product to be considered a product of a particular country, it must have undergone its last substantial transformation within that country. "A textile or textile product will be considered to have undergone a substantial transformation if it has been transformed by means of substantial manufacturing or processing operations into a new and different article of commerce." 19 CFR 12.130(b).

Section 12.130(e)(2), Customs Regulations provides that an article usually will not be considered to be a product of a particular country by virtue of merely having undergone:

(ii) Cutting to length or width and hemming or overlocking fabrics which are readily identifiable as being intended for a particular commercial use;

The simple cutting and seaming (which we assume to be hemming) of the towelling fabric in Honduras falls within the above provision. We do not consider these operations to be substantial manufacturing or processing operations. In addition, the washing, folding and packaging of the towels are considered minor operations which do not effect a change on the article.

The operations which take place in Honduras are minor compared with the weaving of the fabric in Hong Kong and are not sufficient to perfect a change in the country of origin.


The country of origin of the subject surgical towels is Hong Kong. Surgical towels are classified in subheading 6307.90.9010, HTSUSA, which provides for other made up articles, other, other, surgical towels. Surgical towels fall within textile category 369 and are dutiable at 7 percent ad valorem.

The designated textile and apparel category may be subdivided into parts. If so, the 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 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 updated weekly and is available for inspection at your local Customs office.

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


John Durant, Director
Commercial Rulings Division

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