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NY E89338

November 26, 1999

CLA-2-48:RR:NC:SP:234 E89338


TARIFF NO.: 4818.20.0020

Mr. C.R. LeConte
A.N. Deringer, Inc.
15 River Street
Calais, ME 04619-1894

RE: The tariff classification and status under the North American Free Trade Agreement (NAFTA), of paper towels from Canada; Article 509

Dear Mr. LeConte:

In your letter dated November 2, 1999, on behalf of your client, Irving Tissue (Dieppe, NB, Canada), you requested a ruling on the status of paper towels from Canada under the NAFTA.

Your client operates a converting mill at the aforementioned location in Canada, and plans to produce household paper towels there for export to the United States. However, the “raw material” utilized in this operation will be large (101-inch-wide) rolls of Brazilian-made “paper towel stock.” Your client explains the procedure as follows:

The stock rolls (parent rolls) of paper towel are placed onto a reel from which it is unwound; perforated at the desired sheet length; and rewound onto a core. This new “master” roll is then cut length wise to produce 12” rolls which are then wrapped in the appropriate poly packaging. The packages are then packed into cases which are then assembled, configured onto pallets, stretch wrapped with poly film, then labeled and readied for shipment.

As noted by your client, large rolls of paper towel stock are classifiable in heading 4803 of the Harmonized Tariff Schedule of the United States Annotated (HTSUSA), while household paper towels are classifiable in heading 4818, HTSUSA. Although samples were not submitted with your inquiry, it is assumed, based on the descriptions provided, that these headings in fact apply respectively to the “raw material” and finished product involved in the instant operation. The applicable tariff provision for the packaged household paper towels will be 4818.20.0020, HTSUSA, which provides for towels of paper pulp, paper, cellulose wadding or webs of cellulose fibers. The general rate of duty will be 2.6%.

The non-originating material used to make the towels has satisfied the change in tariff classification required under HTSUSA General Note 12(t)/48.6. The towels will be entitled to a free rate of duty under the NAFTA upon compliance with all applicable laws, regulations, and agreements.

This ruling is being issued under the provisions of Part 181 of the Customs Regulations (19 C.F.R. 181).

This ruling letter is binding only as to the party to whom it is issued and may be relied on only by that party.

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 Carl Abramowitz at 212-637-7060.


Robert B. Swierupski

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