CLA-2-63:OT:RR:NC:N3:349
Ms. Ikbal Maya
Atlas National Corp.
6725 Jimmy Carter Blvd., Suite B
Lawrenceville, GA 30071
RE: The tariff classification of shop towels from Pakistan or Bangladesh
Dear Ms. Maya:
In your letter dated November 2, 2018, you requested a tariff classification ruling.
You submitted two samples with your request which you refer to as “rags.” Both samples are identically constructed but differ slightly in size. The samples are rectangular shaped, plain woven towels made from a coarse osnaburg or similar fabric formed from cotton waste. The towels are hemmed on three sides with selvedge along the fourth. The corners are rounded. Both samples submitted are bleached; although, you indicate they may be dyed a uniform color at time of importation, as well. The samples measure approximately 12 X 15 inches; however, you indicate they may range from 12 X 12 inches to 18 X 18 inches. They are imported and sold in bulk, primarily to painting and cleaning companies to remove oil and paint spills or to clean oily machinery or parts.
In your letter, you refer to all of the towels as “rags” and opined they are similar to goods classified under heading 6310, Harmonized Tariff Schedule of the United States (HTSUS). The Explanatory Note for Heading 6310 states, in part: “(1)… Rags may consist of articles of furnishing or clothing or of other old textile articles so worn out, soiled or torn as to be beyond cleaning or repair, of small new cuttings (e.g., dressmakers’ or tailors’ snippings).” Though it is noted that your ruling request indicates the towels may be imported new or used and may be sorted or unsorted, the subject samples are neither old nor soiled. The towels appear to be new, clean and have been deliberately cut and then sewn on three edges with a selvedge along the fourth edge. Neither sample is missing material. If you feel some of the used items to be imported may qualify under this provision, please submit a new ruling request, for further consideration, accompanied by samples of imported towels that you feel meet this definition. In the subsequent ruling request, if the articles from this request will be comingled with articles which are the subject of the new ruling request, please so state. The samples for which this ruling applies, however, do not fall within the guidelines established by the Explanatory Notes to qualify them as rags. The subject samples are considered shop towels and will be classified under subheading 6307.10, HTSUS.
The applicable subheading for the shop towels will be 6307.10.2005, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other made-up articles including dress patterns: Floorcloths, dishcloths, dusters and similiar cleaning cloths: Other: Shop towels dedicated for use in garages, filling stations and machine shops: Of cotton.” The rate of duty will be 5.3 percent ad valorem.
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 the World Wide Web at https://hts.usitc.gov/current.
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 Kim Wachtel at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division