Mr. Edward Comeaux
Comeaux Marketing, Inc.
44043 Stringer Bridge Road
Saint Amant, LA 70774

RE: The tariff classification of a plastic towel from Hong Kong, China, or Thailand

Dear Mr. Comeaux:

In your undated letter that was received in this office on April 28, 2011, you requested a tariff classification ruling.

Each of the two submitted samples is identified as a Poly Vinyl Alcohol Towel. One of the samples is green in color and measures approximately 17” x 26”. The other sample is blue in color and measures approximately 16¼” x 25¾”. Each towel is made of polyvinyl alcohol (PVAL) plastic foam material. There is a reinforcing mesh of monofilament that runs through the center of the entire length and width of the towel and is completely covered by the PVAL material on both sides.

Each towel is packed in a plastic semi-cylindrical lidded container. The towel is pre-moistened with water before packed, which makes it malleable and absorbent. If left out of the container for several hours, it will become dry, hard and stiff. However, when the towel is placed in water, it becomes malleable and absorbent once again. This item is designed for cooling the body and is of the class or kind of merchandise that is principally used in and around the home.

You have asked if this item is correctly classified in subheading 4114.10.0000 and if a visa is required. Subheading 4114.10.0000 provides for chamois leather and this item is made of PVAL which is a plastic material. Therefore, subheading 4114.10.0000 would not be applicable. Also, a visa is not required for the importation of this merchandise.

The applicable subheading for the Poly Vinyl Alcohol Towel will be 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for …other household articles…of plastics: other: other…other. The rate of duty will be 3.4 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

Articles classifiable under subheading 3924.90.5650, HTSUS, which are products of Thailand may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at and search for the term “GSP”.

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 Gary Kalus at (646) 733-3055.


Robert B. Swierupski
National Commodity Specialist Division