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NY A80876

March 21, 1996

CLA-2-63:RR:NC:TP:349 A80876


TARIFF NO.: 6302.60.0030

Mr. Michael D. Weller
Celeste Industries Corporation
Post Office Box 775
Easton, Maryland 21601

RE: The tariff classification of washcloths from China and Pakistan.

Dear Mr. Weller:

In your letter dated February 29, 1996 you requested a classification ruling.

The submitted sample, identified as "Oshibori Refresher Towels", are washcloths. The washcloths are made of 100 percent terry toweling material and they measure approximately 10 inches square. The edges are rolled over and are finished with an overlock stitch. The towels are sprayed with a fragrant chemical. These towels will be imported in a tray containing eight rolled up towels and a tong. The complete tray is then wrapped with clear wrap. These towels are sold to the airline industry.

In your letter, you note that bales of washcloths made in Pakistan and China are sent to the United Kingdom. The following operations are performed in the United Kingdom:

1. the towels are inspected (i.e. thread configuration, discoloration, infestation and other defects.)

2. the towels are sprayed with a proprietary fragrant chemical.

3. the towels are folded and rolled and placed in a tray.

You believe that the above processing is sufficient to cause a substantial transformation and render the washcloth a product of the United Kingdom. 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, each as showerproofing, superwashing, bleaching..." The towels were not subject to a substantial manufacturing or processing operation as noted in Section 12.130 (e). Therefore, the washcloths are considered a product of Pakistan and China.

The applicable subheading for the washcloths will be 6302.60.0030, Harmonized Tariff Schedule of the United States (HTS), which provides for bed linen, table linen, toilet linen and kitchen linen: toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton... towels: other. The duty rate will be 10.1 percent ad valorem.

The washcloths fall within textile category designation 369. Based upon international textile trade agreements products of China are subject to quota and the requirement of a visa. Washcloths from India are only subject the requirement of a visa.

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. 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 Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist John Hansen at 212-466-5854.


Roger J. Silvestri

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