HQ 084034
                                      April 24 1989
             CLA-2 CO:R:C:G  084034  SM
Ms. Dolores Tiongco
             Quintessential Quilts
             578 Westgate Drive
             State College, PA  16803
             RE:  Tariff classification of quilts
             Dear Ms. Tiongco:
                   Your letter of January 20 requests a tariff classifica-
             tion ruling for certain quilts to be made in the Philippines.
             FACTS:
                   You state that you intend to supply to the Philippines
             100 percent cotton U.S. fabric in 25-yard bolts; 100 percent
             polyester batting in 120-inch-square pieces to be cut into 60-
             inch-square pieces; quilting thread; and labels.  We assume
             that all operations necessary to manufacture the finished
             quilts will be performed in the Philippines.  You have also
             submitted a sample quilt.  It is about 52 inches square and
             has a four-inch-wide "sleeve" on the back along one edge.  The
             face displays colorful designs formed by piecing; the back is
             a solid fabric.  A folded bias edging of approximately 8 mm,
             measured to the fold, finishes all four sides.
             ISSUE:
                   How is the quilt classified?
             LAW AND ANALYSIS:
                   Classification under the Harmonized Tariff Schedule of
             the United States Annotated (HTSUSA) is in accordance with the
             General Rules of Interpretation (GRI's).  GRI 1 provides that
             classification is determined first in accordance with the
             headings of the tariff and any relative section or chapter
             notes, and then, if the headings and notes do not require
             otherwise, in accordance with the remaining GRI's.
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                   Heading 9404, HTSUSA, provides for ". . . articles of
             bedding and similar furnishing (for example, mattresses,
             quilts, eiderdowns. . .) fitted with springs or stuffed or
             internally fitted with any material. . . ."  Since no defi-
             nition of quilts is given, the common meaning of the term
             applies:
                        1 b bed coverlet made of two layers of cloth of
                        which the top one is usu. pieced or appliqued and
                        having a filling of wool, cotton, or down held in
                        place by stitched designs or tufts worked through
                        all thicknesses.
                        Webster's Third New International Dictionary Un-
                        abridged
                        1. a bed cover made of two plies of fabric with a
                        filling or wadding of cotton, wool, down, man-
                        made fiber, etc., stitched through in patterns or
                        tufted. . . .
                        Fairchild's Dictionary of Textiles
             Thus, in general a quilt is a bedcover consisting of three
             layers, one of which is a filling, all held together by
             stitching or tufts through all thicknesses.  The submitted
             sample, stated to be a quilt, conforms to this definition and,
             by virtue of its filling, meets the requirements of the tariff
             provision that it be "internally fitted with any material."
                   The subheadings under heading 9404, HTSUSA, providing
             for quilts, eiderdowns and comforters, require that these
             goods be classified as of cotton, of man-made fibers, or of
             other textile materials.  Neither the legal notes nor the
             Explanatory Notes (EN), the official interpretation of the
             HTSUSA at the international level, indicate how this deter-
             mination is to be made in the case of a quilt consisting of
             more than one textile material.  However, Additional U.S. Rule
             of Interpretation 1(d) of the tariff provides that "the
             principles of section XI regarding mixtures of two or more
             textile materials shall apply to the classification of goods
             in any provision in which a textile material is named."
                   Note 2 and Subheading Note 2 of Section XI, which covers
             textiles and textile articles generally, provide that goods of
             this section consisting of two or more textile materials are
             to be regarded as consisting wholly of that textile material
             which predominates by weight over each other single textile
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             material.  Applying this principle to quilts of heading 9404,
             HTSUSA, as directed by U.S. Rule of Interpretation 1(d), we
             conclude that such goods are classifiable according to the
             textile material of which they are in chief weight.
             HOLDING:
                   If the cotton predominates by weight, the quilts are
             classified under subheading 9404.90.9010, HTSUSA, textile
             category 362.  If the man-made fiber predominates, they are
             classified under subheading 9404.90.9020, HTSUSA, textile
             category 666.
                   Because of the changeable nature of the statistical
             annotation, i.e., the ninth and tenth digits of the tariff
             number, and the textile restraint categories, you should
             contact your local Customs office before importation of this
             merchandise to determine the current status of any import
             restraints or requirements.
                                        Sincerely,
John Durant, Director
                                        Commercial Rulings Division