Kathy Zagorski
DSV Air & Sea Inc.
200 Wood Ave S
Iselin, New Jersey 07067

RE: The tariff classification of regenerated cellulose sponge sheets from China

Dear Ms. Zagorski:

In your letter dated July 9, 2021 you requested a tariff classification ruling on behalf of your client, Epare LLC. Representative samples were submitted with your request and were sent to the CBP laboratory for analysis.

Style number EPKA09 is referred to as a Swedish dishcloth. The samples provided are sponge sheets that measure 19.5 cm by 17.5 cm rectangular shapes with 90 degree corners. They are screen printed with various designs, but are not further worked. These reusable sponge sheets will be used for household cleaning purposes, with the goal to reduce the use of paper towels. The sponge sheets will be imported cut to size and packaged for retail sale.

The sponge sheets are manufactured from a mixture of 70 percent cellulose, in the form of viscose, a dissolved liquid cellulose, and 30 percent scrap cotton fibers. The mixture undergoes a several step process, including salting before being extruded into a sheet. The sheet is subjected to a process to regenerate the viscose back into cellulose. It is then treated by indirect steam heating to remove the salt, creating the pores in the finished sponge sheet that increase its absorptive qualities. CBP Laboratory analysis indicates that the sheet is cellular in structure and composed of 63.2 percent cellulose and 36.8 percent cotton fibers. The cellulose is regenerated cellulose. The sheet is printed on the front face, but is not coated, covered or laminated.

The applicable subheading for the regenerated cellulose sponge sheets will be 3921.14.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of plastics: cellular: of regenerated cellulose. The general rate of duty will be 6.5 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3921.14.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.02, in addition to subheading 3921.14.0000, HTSUS, listed above.

The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at and, respectively.

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 the 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 Christina Allen at [email protected]


Steven A. Mack
National Commodity Specialist Division