CLA-2-56:S:N:N6:350 809389

Mr. James Shaw
Lep Profit International
111 Pavonia Avenue
Jersey City, NJ 07310

RE: The tariff classification of a 100% Polyvinyl Alcohol Sheet (nonwoven) from either Korea or China.

Dear Mr. Shaw:

In your letter dated April 14, 1995, on behalf of Quentex Trading Corporation, you requested a classification ruling. The instant sample, identified as PA-4OW, consists of a nonwoven material of water soluble polyvinyl alcohol fibers (PVA). The product is used in embroidery as a ground or base material. After stitching, the PVA backing is dissolved in hot water. The material will be imported as piece goods in rolls of 21 to 64 yards.

You suggest that classification is under item 3920.91.0000, HTS, as a plate, sheet, film, or foil of polyvinyl butyral. No method of manufacture was provided. However, from observation, the material is fibrous in nature and by method of production, the fibers are textile in nature. The material is constructed of staple PVA fibers put down in either a wet laid or dry laid process, creating a web of a nonwoven textile.

The applicable subheading for the material will be 5603.00.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for nonwovens, whether or not impregnated, coated, covered or laminated, of staple fibers. The duty rate will be 10 percent ad valorem.

This merchandise falls within textile category designation 223. Based upon international textile trade agreements products of either China or Korea are subject to quota and the requirement of a visa.

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. Since 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 Customs office.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director
New York Seaport