CLA-2-63:OT:RR:NC:N3:351
Mr. Beau Alewine
Southeast Sourcing, LLC
10213 High Peak Drive
Greenville, SC 29609
RE: The tariff classification of non-moistened facial wipes from China
Dear Mr. Alewine:
In your letter dated October 8, 2025, you requested a tariff classification ruling. A sample of the product was
provided to this office and will be retained for training purposes.
The sample, described as a “plastic jar with a sealable lid, packed with facial wipes,” consists of a
polypropylene container and disposable non-moistened textile pads designed for cleaning one’s face. The
single-layer pads are composed of 100 percent rayon nonwoven fabric. Each round-shaped pad, measuring 2
inches in diameter, features one smooth side and one waffle textured side. The container holds 60 pads and
has a screw-on lid. You state after importation, the container will be filled with facial cleaning solution, and a
sticker label will be adhered to the outside of the jar before distribution for retail sale.
You have suggested that the facial wipes should be classified under subheading 3401.11.5000, Harmonized
Tariff Scheule of the United States (HTSUS), which provides for “Soap; organic surface-active products and
preparations for use as soap, in the form of bars, cakes, molded pieces or shapes, whether or not containing
soap; organic surface-active products and preparations for washing the skin, in the form of liquid or cream
and put up for retail sales, whether or not containing soap; paper, wadding, felt, and nonwovens,
impregnated, coated or covered with soap or detergent: Soap and organic surface-active products and
preparations, in the form of bars, cakes, molded pieces or shapes, and paper, wadding, felt and nonwovens,
impregnated, coated or covered with soap or detergent: For toilet use (including medicated products): Other.”
We disagree. The dry nonwoven wipes do not fall under heading 3401, HTSUS, as they are not impregnated,
coated or covered with soap or detergent.
You have also suggested that the facial wipes should be classified under subheading 5603.93.0090, HTSUS,
which provides for “Nonwovens, whether or not impregnated, coated, covered or laminated: Other: Weighing
more than 70 g/m2 but not more than 150 g/m2: Other.” We disagree. The round nonwoven wipes are
considered “made up” textile articles classified under heading 6307, per Note 7(a) to Section XI of the
HTSUS, as they are cut to a shape other than squares or rectangles.
General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), states in
part that for legal purposes, classification shall be determined according to the terms of the headings, any
relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in
order. GRI 5(a) provides that “camera cases, musical instrument cases, . . . and similar containers, specially
shaped or fitted to contain a specific article or set of articles, suitable for long-term use and entered with the
articles for which they are intended, shall be classified with such articles when of a kind normally sold
therewith. This rule does not, however, apply to containers which give the whole its essential character.” As
noted above, the facial wipes are imported with a plastic container. In the instant case, the plastic container is
specially shaped to accommodate the facial wipes. The container is imported with the facial wipes and is sold
with the facial wipes. Thus, the essential character of the product is the facial wipes rather than the container.
Accordingly, the container is classified with the facial wipes.
The applicable subheading for the “plastic jar with a sealable lid, packed with facial wipes” will be
6307.90.9891, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other:
Other: Other: Other.” The rate of duty will be 7 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 6307.90.9891, 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 from China, Hong
Kong, and Macau will be subject to 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 6307.90.9891, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6307.90.9891, HTSUSA, 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 subheading 6307.90.9891, HTSUSA, 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, available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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/.
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 Kristine Dodge at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division