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January 25, 1999

CLA-2-63:RR:NC:TA:349 D86649


TARIFF NO.: 6302.60.0020

Mr. Max O. Fernandez
FWI Corporation
5777 West Century Boulevard
Suite 1455
Los Angeles, California 90045

RE: The tariff classification of towels from India.

Dear Mr. Fernandez:

In your letter dated January 8, 1999 you requested a classification ruling on behalf of American Textile Systems.

The instant samples, which you refer to as “auto detailing towels” are considered other towels. The towels are made from 100 percent cotton griege terry toweling fabric. All four edges are hemmed. The towels feature uncut loops on both sides. You have indicated that the towels will measure 17 x 30 inches and the submitted towels measure 18.5 x 29 inches.

You refer to the towels as “auto detailing towels”. Auto detail towels are used as cleaning towels for automobiles in the application and removal of wax, shampoo, cleaners, or other liquids. These towels are primarily used in "auto detail" shops which provide services for exterior and interior care of motor vehicles. They are also sold to consumers at car washes, auto supply stores, and department stores. In accordance with GRI 1, such towels are provided for under subheading 6307.10.1000, HTSUSA, as "Dustcloths, mop cloths and polishing cloths, of cotton... ." The EN’s to heading 6307, state that the heading includes, "Floor?cloths, dish?cloths, dusting cloths and similar cleaning cloths ... ." However, the EN’s additionally note that heading 6307 covers only those made up articles of any textile material which are not included more specifically in other headings of Section XI or elsewhere in the Nomenclature. In this case, the towels have dimensions and features which would also render them subject to use as "hand towels" or "dish towels" which are classifiable under 6302.60.00, HTSUSA, as "Toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton; Towels ... ." The Textile Category Guidelines (CIE 13/88 of November 23, 1988) state that dish towels and hand towels fall within the same size range, 24 to 32 inches long and 15 to 18 inches wide. The submitted towels are much larger than those that have been previously classified as cleaning cloths.

You have not provided any evidence to this office such as advertising, places where the item will be sold and retail packing which would clearly specify the use of the towels as “auto detail towels”. Although imported in a greige state, the submitted towels fall within the size range of a dish or hand towel. Following the Textile Category Guidelines, the instant towels will be classified as other towels.

The applicable subheading for the 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 9.7 percent ad valorem.

The towels fall within textile category designation 363. Based upon international textile trade agreements products of India 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 212-466-5854.


Robert B. Swierupski

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