CLA-2-34:OT:RR:NC:2:236

Mr. Todd D. Bulmash
Berlin Packing, LLC
525 West Monroe Street, 14 floor
Chicago, IL 60661

RE: The tariff classification of pre-moistened hand “sanitizer” wipes from Hong Kong

Dear Mr. Bulmash:

In your letter dated November 4, 2010, you requested a tariff classification ruling.

Your literature describes the pre-moistened hand cleaning wipes as containing benzalkonium chloride along with other surfactants and cleaning ingredients. You indicate that the pre-moistened hand “sanitizer” wipes will be used to clean the skin. You state that the pre-moistened hand “sanitizer” wipes are disposables and flushable. Your literature states that the pre-moistened hand cleaning wipes are packed for retail sale in a plastic dispensing container.

The essential character of the pre-moistened hand “sanitizer” wipes is the hand cleaning solution. The wipe is used as a carrier for the hand cleaning solution.

The applicable subheading for the hand “sanitizer” wipes will be 3401.19.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Soap; organic surface-active products and preparations for use as soap, in the form of bars, cakes, molded pieces or shapes, whether or not containing soap; paper, wadding, felt and nonwovens impregnated, coated or covered with soap or detergent: Soap and organic surface-active products and preparations, in form of bars, cakes, molded pieces or shapes, and paper, wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent: Other. The rate of duty will be free.

Perfumery, cosmetic, and toiletry products are subject to the requirements of the Federal Food, Drug and Cosmetic Act, which are administered by the U.S. Food and Drug Administration. You may contact them at U.S. Food and Drug Administration, Office of Cosmetics and Colors, 5100 Paint Branch Parkway, College Park, MD 20740-3835, telephone number 301 436-1130. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Debra Wholey at (646) 733-3034.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division