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HQ 087992

December 28, 1990

CLA-2 CO:R:C:G 087992 CRS


TARIFF NO.: 6302.60.0010; 6302.91.0045

Ms. Cynthia L. Frum
Broker Power, Inc.
Suite 208
1377 K Street, N.W.
Washington, D.C. 20005

RE: Cotton jacquard woven towel with terry loops on terry squares and greige "flour sack" towel classifiable as dish towels. Textile Guidelines. HRL 087918.

Dear Ms. Frum:

This is in reply to your letters dated August 7, 1990, and September 7, 1990, to our New York office, on behalf of your client, Eastern Imports, Ltd., concerning the classification of towels under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). Two samples were submitted with your request.


The merchandise in question consists of two 100 percent cotton towels. The first is made from a jacquard weave fabric with terry loops forming a frame around terry squares. The towel measures approximately 14 inches by 24 inches and is pink in color. All edges are turned and hemmed. The towels will be imported from Sri Lanka and Pakistan.

The second article is made of 100 percent cotton greige material and measures approximately 38 inches by 35 inches. The construction of this article, known as a flour sack towel, is 48 in the warp by 44 in the weft. The greige material is subjected to various finishing operations in the United States. The towels will be imported from India, Pakistan and China. The ports of entry for both towels will be Chicago, Seattle and Charleston.


Whether the towels in question are classifiable in heading 6302, HTSUSA.


Articles are classified under the HTSUSA in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of articles is determined according to the terms of the headings and any relative section or chapter notes and, provided the headings or notes do not otherwise require, according to the remaining GRIs taken in order.

Heading 6302, HTSUSA, provides for bed linen, table linen, toilet linen and kitchen linen. According to the Explanatory Notes, which constitute the official interpretation of the Harmonized System at the international level, the term kitchen linen covers articles such as tea towels and glass cloths.

The jacquard woven terry towel has a design comprised of raised terry squares forming a check pattern. The Guidelines for the Reporting of Imported Products in Various Textile and Apparel Categories, 53 FR 52563, 52564, provide in pertinent part:

Dish towels (category 369) and hand towels (category 363) fall within the same size range, 15 to 18 inches wide and 24 to 32 inches long, and are sometimes difficult to distinguish from each other. 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 mae from a much coarser fabric. These towels may be longer than other dish towels.

Although the towel is made of terry fabric Customs' is of the view that the woven checkered design is indicative of kitchen use and that, consequently, the towel is classifiable at the subheading level under the provision for dish towels.

As for the greige flour sack towel, Customs has previously held that towels of this construction, despite their size, are dish towels and are classifiable accordingly. See Headquarters Ruling Letter 087918 dated December 10, 1990.


The terry towel is classifiable in subheading 6302.60.0010, HTSUSA, under the provision for toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton, towels; dish. The towel is dutiable at the rate of 10.3 percent ad valorem and is subject to textile category 369.

The greige flour sack towel is classifiable in subheading 6302.91.0045, HTSUSA, under the provision for other; of cotton; other; towels; other; dish. The towel is dutiable at the rate of 10.5 percent ad valorem and is subject to textile category 369.

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.

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.


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