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NY 877599

August 28, 1992
CLA-2-:S:N:N3H:350 877599


TARIFF NO.: 5601.21.0090

Mr. Rudy A. Pina
R.A. Pina & Associates, Inc.
P.O. Box 2496
Nogales, AZ 85628

RE: The tariff classification of cotton swabs for general hygiene use, from Mexico.

Dear Mr. Pina:

In your letter dated August 14, 1992, on behalf of Labor International, you requested a tariff classification ruling.

You state in your correspondence that these swabs begin their manufacture with polypropylene pellets of U.S. origin that are sent to Mexico where they undergo an extrusion process. The pellets are extruded into long polypropylene sticks which are referred to as "straws". Once these polypropylene straws have cooled, they are cut to lengths of 73mm and from that point on are referred to as "sticks". After these sticks are cut to length, the ends of the sticks are wrapped with cotton. This cotton, which is of U.S. origin, is first carded in the U.S. with the resulting sliver coiled by a continuous circular motion. The cotton is then bagged and placed into shipping cartons of approximately 17 pounds each before being sent to Mexico. The finished swabs in Mexico are finally dried and put up in blister packs for their ultimate sale.

While you mention the word assembly in your letter, no allowance in duty can be made for the U.S. supplied components due to the extensive manufacturing operations that were performed on the raw materials in Mexico.

The applicable subheading for the swabs, therefore, will be 5601.21.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for articles of cotton wadding. The rate of duty will be 7.2 percent ad valorem.

While these swabs fall within textile category designation 369, they are not subject to either quota or the requirement of a visa at the present time.
This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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