CLA-2-96:OT:RR:NC:4:434
Pegah Nabili
Covington and Burling LLP
One CityCenter
Washington DC 20001
RE: The tariff classification of feminine hygiene products from Mexico
Dear Ms. Nabili:
In your letter, dated March 17, 2025, you requested a tariff classification ruling on behalf of your client,
Kimberly Clark Global Sales LLC. Samples and a description of the item were submitted for our review.
This letter will be given confidential treatment based on the facts you supplied to support your claim for
exemption from disclosure.
The products under consideration are “Click Compact Tampons.” The tampons come in three levels of
absorbency, Regular, Super, and Super Plus, and are packaged together in a “multipak” retail box. The
applicators, which are made of plastic, consist of a barrel, a telescopic tube, and a plunger. The tampons
have an inner core of textile wadding, which, per your submission, is rayon. This core has a nonwoven
overwrap cover of semi-synthetic material.
When examined, the inner rayon core meets the definition of “textile wadding,” as defined in the Explanatory
Notes to Chapter 56, HTSUS, which state:
(A) WADDING OF TEXTILE MATERIALS AND ARTICLES THEREOF
The wadding referred to here is made by superimposing several layers of carded or airlaid textile fibres one
on the other, and then compressing them in order to increase the cohesion of the fibres…
Wadding takes the form of a flexible, spongy, highbulk sheet, of even thickness, the fibres in which are
readily separable. It is generally made of cotton fibres (absorbent or other cotton waddings) or of artificial
staple fibres…
You propose classification in subheading 9619.00.1510, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Sanitary pads (towels) and tampons, diapers (napkins), diaper liners and
similar articles, of any material: Of paper, cellulose wadding or webs of cellulose fibers: Sanitary napkins
and tampons.” Alternately, you propose 9619.00.2500, HTSUS, the above heading: “Of textile wadding.”
Rayon is a textile fiber. Despite originating from cellulose, it is processed in such a way that a textile fiber is
formed. Per review of the sample’s "inner core" material, the construction is consistent with that of textile
wadding.
Therefore, the applicable subheading for the multipak of tampons will be 9619.00.2500, HTSUS, which
provides for “Sanitary pads (towels) and tampons, diapers (napkins), diaper liners and similar articles, of any
material: Of textile wadding.” The column one, general rate of duty will be 6.3 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 the World Wide Web at https://hts.usitc.gov/current.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 9619.00.2500,
HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 9619.00.2500.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 Charlene Miller at
[email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division