Ms. Jane Taeger
Samuel Shapiro and Company, Inc.
100 North Charles St.
Suite 1200
Baltimore, MD 21201

RE: The tariff classification of three coated or laminated fabrics from China

Dear Ms. Taeger:

In your letter dated November 4, 2014, you requested a tariff classification ruling. You submitted samples of three fabrics. New York Ruling N257014 is noted.

Style Piano Cover is a bonded fabric consisting of two fabric layers, one black and one white. The adhesive that bonds the layers together is not visible in cross section. Although you state in your letter that the black fabric layer is woven, U.S. Customs and Border Protection (CBP) laboratory analysis finds that this laminated fabric consists of a black polyester filament fabric of single yarn weft knit construction weighing 155.2 g/m2, which has been bonded to a white needleloom felt fabric of polyester staple fibers weighing 253.1 g/m2. The needleloom felt is made by punching the webs together without a textile fabric base. No other thermal or chemical bonding methods have been used in the manufacture of the white fabric.

In your letter you suggest classification of the laminated fabric as a nonwoven fabric under heading 5603, Harmonized Tariff Schedule of the United States (HTSUS), stating that you feel that it is the nonwoven layer which imparts the essential character to the bonded fabric because when the fabric is used as a piano cover, it is the nonwoven side which rests on the piano surface to prevent scratches in the wood, which is the primary purpose of the piano cover. However, CBP lab analysis has determined that the white layer is a needleloom felt fabric.

The applicable subheading for Style Piano Cover will be 5602.10.1000, HTSUS, which provides for Felt, whether or not impregnated, coated, covered or laminated: Needleloom felt and stitch-bonded fiber fabrics: Laminated fabrics. The rate of duty will be 12% ad valorem.

Style Royal Touch is woven fabric which has been visibly coated on one side. CBP lab analysis indicates that this fabric is composed of a woven fabric (70.5 g/m2, or 25% by weight) which has been coated on the outer surface with a polyvinyl chloride (PVC)-type plastic material of compact structure (211.0 g/m2, or 75% by weight), for a coated fabric weight of 281.5 g/m2. The woven fabric is composed wholly of nylon yarns and is of plain weave construction.

The applicable subheading for Style Royal Touch will be 5903.10.2090, HTSUS, which provides for Textile fabrics impregnated, coated covered or laminated with plastics, other than those of heading 5902: With poly(vinyl chloride): Of man-made fibers: Other: Over 70 percent by weight of rubber or plastics, Other. The rate of duty will be Free.      

Style No Slip is a knit fabric which has been visibly coated on one side. CBP lab analysis indicates that the fabric is of weft knit construction, composed wholly of polyester yarns, and weighs 64.3 g/m2, or 11.8% by weight. The fabric has been combined with a PVC-type plastic material of cellular structure weighing 479.3 g/m2, or 88.2% by weight. The polyester textile material serves as reinforcement to the sheet of textured cellular polyvinyl chloride (PVC) plastic layer.

The applicable subheading for Style No Slip will be 3921.12.1100, HTSUS, which provides for Other plates, sheets, film, foil and strip, of plastics: Cellular: Of polymers of vinyl chloride: Combined with textile materials: Products with textile components in which man-made fibers predominate by weight over any other single textile fiber: Over 70 percent by weight of plastics. The rate of duty will be 4.2% 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

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 Maribeth Dunajski at [email protected].


Gwenn Klein Kirschner
National Commodity Specialist Division