CLA-2-34:OT:RR:NC:N3:136
William Maloney
Sandler, Travis & Rosenberg, P.A.
286 Madison Avenue - Suite 1200
New York, NY 10017
RE: The tariff classification and country of origin of Lens Cleaning Wipes
Dear Mr. Maloney:
In your letter dated January 28, 2026, on behalf of your client, HTA Direct Sourcing, you requested a tariff
classification and country of origin determination ruling.
In your submission, the subject products are described as pre-moistened lens cleaning wipes identified as
“Lens Cleaning Wipes,” Item # 1064689 (foil wrapped) and Item #1064690 (pop-up container). The
disposable cleaning wipes are composed of a basesheet of tissue paper made from wood pulp cellulose that
serves as the carrier for a cleaning solution, which is a mixture of water, isopropyl alcohol, and other
chemicals including a surfactant.
The pre-moistened wipes are used by consumers to clean prescription eyeglass lenses, sports goggles,
sunglasses, scopes, CD’s, DVD’s, etc. The wipes will be imported in following two packaging
configurations:
(1) Individual wipe foil wrapped: The rectangular foil wrapped wipes will be imported in two sizes that
measure approximately 6"x5" or 7"x5". The small individual sheets are saturated with the sterile cleaning
solution. The wipes are folded, packaged into individual foil packets, and boxed for sale.
(2) Pop-up container: a pop-up container with a roll of 100 wipes perforated, so each sheet tears apart from
the roll of 100 as the consumer pulls a sheet from the container. The rectangular wipes on the perforated roll
will measure approximately 5.11" x 7.8". The individual sheets are saturated with the sterile cleaning solution
.
The paper that serves as the carrier for the cleaning solution is described as cellulose-based Lens Cleaning
Wipes, medical/optical grade, that has a wet strength of 40 GSM. The paper will be manufactured in China
from wood pulp. The pulp is dispersed in water and mechanically refined to achieve the right fiber length and
bonding ability. The nonwoven sheet will be created using either a mechanical or air process.
We agree that the cleaning solution imparts the wipe’s essential character, while the nonwoven sheet serves
as the carrier.
The applicable subheading for the Lens Cleaning Wipes will be 3401.19.0000, Harmonized Tariff Schedule
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 sale, 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: Other. The general rate of duty will be free.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
Country of Origin
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc.
v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence.
See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
You indicate that the cleaning solution will be produced in either Taiwan, Indonesia, Japan, or Korea and
shipped to China. In China, wood pulp jumbo rolls are unrolled and cut (length and width) into individual
rectangular pieces of 5"x 7" or 5"x 6”. These small individual sheets are then saturated with the sterile
cleaning solution. Lastly, the individual sheets are folded, packaged into individual foil packets, and boxed
into cases containing either 1,000 or 3,000 individual foil wrapped wipes. For the pop-up container wipes, the
jumbo rolls are cut into lengths and perforated so that each cut piece has 100 pull apart towelettes. These 100
towelette units are saturated with the sterile cleaning solution. Lastly, the individual sheets are rolled and
placed into the pop-up container.
Regarding the country of origin of the Lens Cleaning Wipes, it is our view that the cleaning solution imparts
the wipe’s essential character. The processing in China, which includes cutting and perforating the
nonwovens to size, impregnating the cleaning solution into the Chinese nonwovens, and packaging
processes, do not result in a substantial transformation of the concentrated cleansing solution. Therefore, it is
the opinion of this office that the country of origin of the Lens Cleaning Wipes will be either Taiwan,
Indonesia, Japan or Korea, based on where the cleaning solution is sourced.
This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health
Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are
administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and
Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by
visiting their website at www.fda.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 Nuccio Fera at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division