Ms. Carla Cravalho
Hellmann International Forwarders, Inc.
448 Grandview Drive
South San Francisco, CA 94080
RE: The tariff classification of a washable breast pad from China.
Dear Ms. Cravalho:
In your letter dated September 25, 1998, on behalf of Mantex
Trading, Inc., you requested a classification ruling.
The submitted sample is a washable breast pad that is used to
prevent leakage of breast milk in breast feeding mothers. The item
is made of four layers of fabric consisting of an outer layer of
100% nylon lace fabric, a woven 100% polyester fabric lining, 100%
polyester fabric padding and a bottom layer of woven 100% cotton
General Rule of Interpretation (GRI) 3(b) states that
"Mixtures, composite goods consisting of different materials or
made up of different components, and goods put up in sets for
retail sale, which cannot be classified by reference to 3(a), shall
be classified as if they consisted of the material or component
which gives them their essential character, insofar as this
criterion is applicable."
In the instant case the item's purpose is to keep bras and
garments dry by absorbing breast milk. The portion of the breast
pad that touches the skin and allows for absorption, that is the
bottom layer of cotton fabric, gives the item its essential
The applicable subheading for the washable breast pad will be
6217.10.9510, Harmonized Tariff Schedule of the United States
(HTS), which provides for "Other made up clothing accessories;
parts of garments or of clothing accessories, other than those of
heading 6212: Accessories: Other: Other...Of cotton." The duty
rate will be 15.1% ad valorem.
The washable breast pad falls within textile category
designation 359. Based upon international textile trade agreements
products of China are subject to quota and the requirement of a
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
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 Kenneth Reidlinger at
Robert B. Swierupski