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NY 896741

April 22, 1994

CLA-2-63:S:N:N6:349 896741


TARIFF NO.: 6302.91.0045

Ms. Martha Sachs
Arden Companies
Suite 201
26899 Northwestern Highway
Southfield, MI 48034

RE: The tariff classification of a flour sack towel from Pakistan.

Dear Ms. Sachs:

In your letter dated March 31, 1994 you requested a tariff classification ruling.

The submitted sample is a white plain woven flour sack towel. It is made of 100 percent cotton woven fabric and measures approximately 22 inches by 37 inches. All four edges of the towel are hemmed.

In your letter, you note that woven greige fabric made in Pakistan is sent to Sri Lanka where it is further processed. The following operations are performed in Sri Lanka:

1. Bleaching of fabric
2. Cutting and hemming of fabric
3. Assembling, packing, and shipping of towels

Section 12.130 (e) of the Customs regulations (19 CFR 12.130) states in part..."An article or material usually will not be considered to be a product of a particular foreign territory or country, or insular possession of the U.S. by virtue of merely having undergone any of the following: (i) simple combining operations, labeling, pressing cleaning or dry cleaning, or packaging operations, or any combination thereof; (ii) cutting to length or width and hemming or overlocking fabrics which are readily identifiable as being intended for a particular commercial use...(iv) one or more finishing operations on yarns, fabrics, or other textile articles, such as showerproofing, superwashing, bleaching,..." The flour sack towel was not subject to a substantial manufacturing or processing operation as noted in Section 12.130 (e). Therefore, it is considered a product of the country where the fabric was produced in this case a product of Pakistan.

The applicable subheading for the flour sack towel will be 6302.91.0045, Harmonized Tariff Schedule of the United States (HTS), which provides for bed linen, table linen, toilet linen and kitchen linen: other: of cotton... other: towels: other: dish. The rate of duty will be 10.5 percent ad valorem.

The towel falls within textile category designation 369. Based upon international trade agreements, products of Pakistan are subject to visa and quota requirements.

The designated textile and apparel categories 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.

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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