CLA-2-63:OT:RR:NC:N2:349
9903.01.25; 9903.02.26; 9903.02.51; 9903.88.15
Kemo Danso
ISA-TRAESKO GmbH
Oderstraße 9
Neumünster 24539
Germany
RE: The tariff classification of duvet cover, dish towel, fitted sheet, beach towel and hand towel from
Pakistan, India and China
Dear Mr. Danso:
In your letter dated August 7, 2025, you requested a tariff classification ruling, for various knitted and woven
household textile articles which will be imported into the United States. Your letter was accompanied by five
samples. The samples will be retained by this office.
Item #1, Article #20011-01, described as “Reinforce Bed Linen R,” is a duvet cover made from 100 percent
cotton woven fabric. The fabric is not napped. The duvet cover features a printed floral, bird and branch
design on the front and back; knife edges; and an opening at the bottom end with a zipper closure. It does not
contain any embroidery, lace, braid, edging, trimming, piping or applique work. The duvet cover measures
approximately 86 x 56 inches and will be imported from Pakistan.
Item #2, Article #20254-01, described as a “Supersoft Fitted Sheet,” is a fitted sheet made from 94 percent
cotton and 6 percent elastane knit fabric. The sample is dyed a sage green color. The fitted sheet is hemmed
with fully elasticized edges. It does not contain any embroidery, lace, braid, edging, trimming, piping or
applique work. The fitted sheet measures approximately 55 x 79 inches and will be imported from Pakistan.
Item #3, Article #20171-01, described as “Spring Dishtowels 3-Pack/2-Pack,” is a set of dish towels made
from 100 percent cotton woven fabric. The fabric for the first towel features a two-tone pink color
checkerboard design and the second towel features a two-tone pink color striped design. You state the
dishtowels are jacquard figured. All the edges are hemmed and a small loop to hang is sewn along the top
center back edge. You state that the dish towels will be also offered in either a 2-pack or 3-pack set. The
intended use of the towel is to dry dishes. The dish towels measures approximately 25 x 17 inches and will
be imported from India.
Item # 4, Article #20292-01, described as “Beach Towel Disney® License” is a towel made from 100 percent
cotton woven fabric. The face of the towel is velour (sheared loops) while the back has terry loops. The face
is printed with the Little Mermaid character Arial from Disney®. All of the edges are hemmed. The towel
measures approximately 28 × 59 inches and will be imported from China.
Item #5, Article #20835-01, described as “Premium Hand Towel with Whipstitch Detail” is a hand towel
made from 100 percent cotton woven terry toweling fabric. All four sides of the towel are serged. The hand
towel measures approximately 36 x 19 inches and will be imported from Pakistan.
You suggest that the Article #20011-01, described as a “Reinforce Bed Linen R,” should be classified under
subheading 6302.21.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“Bed linen, table linen, toilet linen and kitchen linen: Other bed linen printed: Of cotton: Other: Not
napped… Other.” We agree. The duty rate will be 6.7 percent ad valorem.
You suggest that the Article #20254-01, described as a “Supersoft Fitted Sheet,” should be classified under
subheading 6302.31.9020, HTSUS, which provides for “Bed linen, table linen, toilet linen and kitchen linen:
Other bed linen, printed: Of cotton: Other: Not napped: Sheets.” We disagree. The fitted sheet is constructed
of knit fabric and is specifically provided for under subheading 6302.10, HTSUS.
The applicable subheading for Article #20254-01, described as a “Supersoft Fitted Sheet,” will be
6302.10.0008, HTSUS, which provides for “Bed linen, table linen, toilet linen and kitchen linen: Bed linen,
knitted or crocheted: Of cotton: Sheets.” The duty rate will be 6 percent ad valorem.
You suggest that the Article #20171-01, described as “Spring Dishtowels 3-Pack/2-Pack” should be
classified under subheading 6302.91.0005, HTSUS, which provides for “Bed linen, table linen, toilet linen
and kitchen linen: Other: Of cotton...Of pile or tufted construction: Towels: Dish.” We disagree. The dish
towels are not constructed of a pile or tufted fabric, therefore, subheading 6302.91.0005 is not appropriate.
The applicable subheading for Article #20171-01, described as “Spring Dishtowels 3-Pack/2-Pack” will be
6302.91.0035, HTSUS, which provides for “Bed linen, table linen, toilet linen and kitchen linen: Other: Of
cotton: Other: Towels: Jacquard figured.” The duty rate will be 9.2 percent ad valorem.
You suggest that the Article #20292-01, described as “Beach Towel Disney® License,” and Article
#20835-01, described as “Premium Hand Towel with Whipstitch Detail,” should be classified under
subheading 6302.60.0020, HTSUS, which provides for “Bed linen, table linen, toilet linen and kitchen linen:
Toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton: Towels: Other.” We agree.
The rate of duty will be 9.1 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 6302.60.0020, HTSUS, listed above.
Effective August 27, 2025, Executive Order 14339 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.84, in
addition to subheading 6302.91.0035, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of China, Hong
Kong, and Macau will be assessed an additional ad valorem rate of duty of 10 percent. At the time of entry,
you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition
to subheading 6302.60.0020, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of India will be
assessed an additional ad valorem rate of duty of 25 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.26, in addition to subheading
6302.91.0035, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Pakistan will be
assessed an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.51, in addition to subheading
6302.21.9050, 6302.10.0008, and 6302.60.0020, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 6302.60.0020, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.15, in addition to subheadings 6302.60.0020 HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
Importations of Article #20292-01, described as “Beach Towel Disney® License,” may be subject to the
provisions of Section 133 of the Customs Regulations if they copy or simulate a registered trademark, trade
name or copyright recorded with U.S. Customs and Border Protection. If you are an authorized importer of
the product we recommend notifying your local Customs office prior to importation.
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 and Border Protection
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, please contact
National Import Specialist Kim Wachtel at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division