Catherine M. Carney
Livingston International
300 East Main Street, Suite 1200
Norfolk, VA 23510

RE: The tariff classification of cotton bale wrap from Israel

Dear Ms. Carney:

In your letter dated January 9, 2017 you requested a tariff classification ruling. Representaive samples of the individual components were submitted with your request and will be returned to you.

The merchandise under consideration are Tama Round Module Wraps, also referred to as Z-Lockā„¢ RMW. Imported in rolls of 24, these products are designed to be loaded into a cotton picking machine for wrapping round modules of cotton during the harvesting process.

Individually, the wraps measure 21 meters long, 227 centimeters wide and 75 microns thick. Slightly tapered at the beginning and the end, each wrap consists essentially of a 7-layer non-tacky Linear Low Density Polyethylene (LLDPE) film which first wraps around the cotton unitizing the bale without sticking to it and a 4-layer LLDPE film which is tacky on one side. Combined, these layers ensure that the module will hold its uniformity during packaging and transport and also provide protection against the elements. In addition, the wraps contain 4 RFID tags which enable tracking of the individual bales and a metallic label that activates the Z-lock separation mechanism at the end of the wrap. Based on the information provided, it appears that Tama Round Module Wraps are composite goods, the essential character of which is imparted by the LLDPE film.

The applicable subheading for the cotton bale wrap will be 3923.90.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics: Other: Other. The general rate of duty will be 3 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

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 April Cutuli at april.a.cutuli


Steven A. Mack
National Commodity Specialist Division