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NY C88294

June 17, 1998

CLA-2-63:RR:NC:TA:349 C88294


TARIFF NO.: 6302.60.0020

Ms. Diana D. Drileck

Revere Mills, Inc.

7313 North Harlem Avenue

Niles, Illinois 60714

RE: The tariff classification of a towel blank and tie towel from China.

Dear Ms. Drileck:

In your letter dated May 19, 1998 you requested a classification ruling.

The submitted samples are a towel blank and tie towel. The plain white towel blank is made from 100 percent cotton terry toweling fabric. It measures approximately 16 x 24 inches. Two sides are hemmed and the other two have a fringe. One side of the towel is sheared and the other contains uncut loops. The words "Revere Mills Kitchen Towel" are printed in small lettering on the sheared side of the towel.

The tie towel is comprised of a padded top portion and a terry towel bottom portion. The top portion is a trapezoid in shape and consists of a foam pad center covered by woven fabric. It has two tie strings on the top portion. Attached to the bottom of the pad is a towel made of 100 percent cotton terry toweling fabric. The towel is folded in half and measures approximately 11-3/4 inches by 14-3/4 inches. The front of the towel is sheared and printed. The back of the towel has unsheared loops. The samples are being returned.

In your letter you indicate that the blank towel will be printed domestically and used as a kitchen towel. However, in the condition imported, the towel could be considered a hand towel. In Headquarter Ruling Letter (HRL) 089951 dated October 29, 1991 Customs addressed the issue of plain white towels. HRL 089951 states in part...."The Guidelines for the Reporting of Imported Products in Various Textile and Apparel Categories (the Guidelines), 53 Federal Register 52563, were developed to facilitate statistical classification and the determination of the appropriate textile categories. The Guidelines state in pertinent part: The dish towels that usually do not have a design are light weight, plain woven, nonpile cotton towel... In the event that no clear distinction based on pattern, design, or otherwise can be made, the article will be classified as an "other" towel in category 363 because it is readily susceptible to more than one use."

The small size of the letters used in printing the word "Kitchen Towel" does not limit the instant towel to a specific use. Following the reasoning in HRL 089951, the towel will be classified as an "other" towel.

The applicable subheading for the blank towel and tie towels will be 6302.60.0020, 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 9.8 percent ad valorem.

The towels fall within textile category designation 363. Based upon international textile trade agreements products of China are subject to quota and 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-



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