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NY 894923

March 7, 1994

CLA-2-56:S:N:N6:350 894923


TARIFF NO.: 5601.21.0010; 5601.21.0090; 5601.22.0010; 5601.22.0090

Mr. Lewis O. Crawford
Crawford International Corp.
1507 Dennbriar Drive
Corcord, NC 28027

RE: The tariff classification of four "cotton wool" (cotton wadding) products from the Republic of South Africa.

Dear Mr. Crawford:

In your letter dated January 31, 1994, you requested a tariff classification ruling. The manufacturer of these products is stated to be Felt Industries (Pty) Ltd., Jacobs, S.A.

The first item consists of cotton wadding which will be imported in rolls about 12" wide. This material consists of a web of wadding measuring approximately 1" in overall thickness when the roll is unfurled. This wadding has been rolled with a paper liner and in its compressed packaged condition, the material measures only about 1/8" thick.

The second item consists of cotton swabs measuring approximately 80mm x 80mm with rounded corners. They are flat pieces about 1/8" thick and have been embossed with a design.

The third item consists of cotton balls measuring about 1" in diameter.

The fourth and final item consists of pleated cotton containing perforations measuring about 1.5" apart. This allows easy separation into rectangular sections measuring about 1.5" x 5". This material is considered to be piece goods.

Your letter refers to the following put-ups for the four items:

Product Line Size/Line Item

Rolled Cotton Wool (Grade 25g
1 plain white roll stock) 50g "
125g "
250g "
500g "

Pleated Cotton Wool (also 50g 250
PKT/cs referred to as Grade 1 100g
180 PKT/cs
Zig Zag)

Cotton Wool Swabs 80mm x 80mm

Cotton Balls (Grade 1 100g/PKT (white)
Medium cotton balls 100g/PKT (mixed " each 1 gram) colors)

These products have a multitude of uses ranging from medical use to home use. The packaging, however, does not indicate any specific intended uses.

With respect to your question about U.S. raw cotton shipped to the Republic of South Africa for further fabrication into such items as are described above, no allowance can be made for the cost or value of the U.S. supplied material noting that the raw material has been further manufactured.

The applicable subheading for the cotton wadding in rolls and the pleated cotton will be 5601.21.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for wadding of cotton, in the piece. The rate of duty will be 7.2 percent ad valorem.

The applicable subheading for the cotton swabs and balls will be 5601.21.0090, HTS, which provides for articles of cotton wadding. The duty rate is 7.2 percent ad valorem.

You also ask the classification if these products were made from a blend of cotton and rayon man-made fibers. If rayon, a man-made fiber, is in chief (greater) weight, the rates of duty become 12.5 percent ad valorem under tariff items numbers 5601.22.0010 and 5601.22.0090, respectively. You further note that these products could be sterilized using gamma radiation. This probably would not change the classification, however, you should present this as a separate issue, giving details on how processed, packaged and to whom sold.

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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