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HQ 084794


September 7, 1989

CLA-2 CO:R:C:G 084794 JBW

CATEGORY: CLASSIFICATION

TARIFF NO.: 6307.10.1000

Ms. Ruby L. Wood
Vice President
Evans and Wood & Co., Inc.
P. O. Box 610005
D/FW Airport, Texas 75261

RE: Classification of Auto Detail Towel

Dear Ms. Wood:

Your letter of May 11, 1989, on behalf of Win-Tex Products, Inc., addressed to our district office in Dallas, Texas, has been referred to this office for a binding ruling on the classification of "auto detail" towels under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).

FACTS:

The sample submitted for classification is a white cotton cloth of low quality terry construction and with hemmed edges. The article measures 38 by 40 centimeters. You state in your letter that the intended use of merchandise is as a cleaning cloth for auto detail shops, but that the cloth may be purchased for other uses.

ISSUE:

What is the classification of cotton terry cloth used principally as cleaning towels in auto detail shops?

LAW AND ANALYSIS:

The General Rules of Interpretation (GRI's) set forth the legal framework in which merchandise is to be classified under the HTSUSA. GRI 1 requires that classification be determined first according to the terms of the headings of the tariff and any relative section or chapter notes and, unless otherwise required, according to the remaining GRI's taken in order.

You state that the merchandise under consideration will be used principally as cleaning towels for "auto detail" shops. Generally, "auto detail" shops provide services for care of the exterior and interior of automobiles and vans. These services include washing and waxing the exterior, applying stripes or decals, cleaning the engine, shampooing the carpeting, and polishing the interior. The merchandise under consideration would be used to apply and remove wax, shampoo, cleaners, or other liquids or to be used as a cloth to remove dust or dirt. Other uses of a towel of this size and construction would be as a cleaning cloth to remove dirt or absorb liquids.

Heading 6307.10, HTSUSA, governs other made up articles, including floorcloths, dishcloths, dusters, and similar cleaning cloths. Note 7 to Section XI defines "made up" to mean, inter alia, hemmed or with rolled edges. Therefore, the merchandise under consideration falls under this heading, for it is "made up," and its principal use is as a cleaning cloth. Subheading 6307.10.1000 includes dustcloths, mop cloths, and polishing cloths of cotton. The use of the merchandise is principally for polishing, dusting, and mopping and is therefore classified under this heading.

Heading 6307 also includes a breakout for shop towels. The subheading specifies that shop towels are those towels dedicated to use in garages, filling stations, and machine shops. Shop towels are always of plain woven, non-pile construction, and thus, the merchandise under consideration is not classifiable under this subheading.

HOLDING:

The cotton terry cloth towel used for cleaning in "auto detail" shops is classified under subheading 6307.10.1000, HTSUSA, and falls within textile category 369.

Due to the changeable nature of the statistical annotation (the ninth and tenth digits of the classification) and the restraint (quota/visa) categories, you should contact your local Customs office prior to importation of this merchandise to determine the current status of any import restraints or requirements.

Sincerely,

John Durant, Director
Commercial Rulings Division

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