David PrataOHL International at CVS Health
Mail Code 1049
1 CVS Drive
Woonsocket, RI 02895
RE: The tariff classification of cleaning products from China
Dear Mr. Prata:
In your letter dated September 25, 2015, you requested a tariff classification ruling. Samples were provided, and will be returned to you.
The merchandise at issue consists of three separate styles of cleaning pad, identified by CVS item numbers 706194, 395014, and 395009.Item 706194, labeled as an Extra Strength Cleaning Eraser, is a box of two rectangular sponges, each measuring approximately 4.9" x 2.4" x 0.7". The sponges, constructed of cellular melamine plastic, feature a textured surface on one side and contain no cleaning agents or abrasives.
Item 395014, labeled as Deep Cleaning Pads, is a box of 12 disposable nonwoven pads designed for use with power mops such as the Swiffer® Wetjet® for household cleaning. Based on the information provided, the pads consist of nonwoven polyester front and rear sheets, surrounding an absorbent core formed from 70% wood pulp and 30% ethylene propylene. The pads are similar in form and function to the product described in Headquarters Ruling Letter H005073, dated January 14, 2011.Item 395009, labeled as Wet Mopping Cloths, is a box of 12 disposable nonwoven cloths that are pre-saturated with a cleaning liquid and are designed for use with manual mops such as the Swiffer® sweeper mop. Based on the information provided, the cloths consist of nonwoven polyester front and rear sheets, surrounding an absorbent core formed from 70% wood pulp and 30% ethylene propylene. You suggest classification of the wet mopping cloths in subheading 5603.14, which covers nonwovens, weighing more than 150 g/m2. The cloths, however, are assembled from several sheets of nonwoven materials bonded together, which meets the definition of a “made up” article as noted in Section XI, Note 7(f). As a result, they are precluded from being classified in heading 5603.
The applicable subheading for the Extra Strength Cleaning Eraser will be 3921.19.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other plates, sheets, film, foil and strip, of plastics: Cellular: Of other plastics. The rate of duty will be 6.5% ad valorem.
The applicable subheading for the Deep Cleaning Pads will be 8509.90.5500, HTSUS, which provides for Electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508; parts thereof: Parts: Other: Other. The rate of duty will be 4.2% ad valorem.
The applicable subheading for the Wet Mopping Cloths will be 6307.90.9889, HTSUS, which provides for other made up textile articles, other. The rate of duty will be 7% 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 http://www.usitc.gov/tata/hts/.
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 Evan Conceicao at email@example.com.
Gwenn Klein Kirschner
National Commodity Specialist Division