Mr. Richard M. Wortman
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP
707 Wilshire Blvd., Suite 4150
Los Angeles, CA 90017

RE: The tariff classification of a towel from China

Dear Mr. Wortman:

In your letter dated August 18, 2008 you requested a classification ruling on behalf of Warnaco, Inc.

The submitted sample is referred to as the Speedo® brand Deluxe Sports Towel, Style number 7530310. The micro fiber towel is made from 80 percent polyester and 20 percent nylon flat woven fabric. It is napped on both sides and finished with an overlock stitch. The towel measures approximately 15 ½ x 27 ¾ inches and features a printed Speedo® logo near one corner. You note that the towel is specially designed for water sports and will absorb many times its weight in water.

You suggest classification under subheading 6307.90.9884, HTSUS, as other towels of man-made fibers under the other made up textile articles provision and cite several rulings. The towels in those rulings, while made from a similar fabric, were also used for cleaning, drying cars, wiping kitchen spills, cleaning golf clubs, etc. The instant towel is used to dry a person after swimming. It is more akin to the towels that are provided for as toilet linen and will be classified as such.

The applicable subheading for the towel will be 6302.93.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for bed linen, table linen, toilet linen and kitchen linen: other: of man-made fibers: other. The duty rate will be 9.9 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 World Wide Web at

The towel falls within textile category 666. With the exception of certain products of China, quota/visa requirements are no longer applicable for merchandise which is the product of World Trade Organization (WTO) member countries. Quota and visa requirements are the result of international agreements that are subject to frequent renegotiations and changes. To obtain the most current information on quota and visa requirements applicable to this merchandise, we suggest you check, close to the time of shipment, the “Textile Status Report for Absolute Quotas” which is available on our web site at For current information regarding possible textile safeguard actions on goods from China and related issues, we refer you to the web site of the Office of Textiles and Apparel of the Department of Commerce at

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 John Hansen at (646) 733-3043.


Robert B. Swierupski
National Commodity Specialist Division