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HQ 960648




October 17, 1997

CLA-2 RR:TC:TE 960648 ASM

CATEGORY: CLASSIFICATION

Tariff No.: 6307.10.1000

J. Nicole Bivens Collinson
Sandler, Travis & Rosenberg, P.A.
1341 G. Street, N.W.
Washington, D.C. 20005-3105

RE: Tariff Classification for Cotton Towels

Dear Ms. Bivens Collinson:

This letter concerns the request for a binding ruling regarding the tariff classification of cotton terry towels under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).

FACTS:

The subject articles are 100 percent cotton woven terry towels measuring approximately 14 x 24, 14 x 26, and 14 x 28 inches. The towels will be imported in solid colors such as white, burgundy, brown, black and green and are hemmed on all four sides. They will be imported prepackaged in a polybag with each bag containing 12 towels. The outside of the bag will indicate the name "PARTEX", fiber content, RN#, origin and the phrase "Auto Detail Towel - 12 PCS/pack."

ISSUE:

What is the proper tariff classification for the subject cotton terry towels under the HTSUSA?

LAW AND ANALYSIS:

Classification of goods under the HTSUSA is governed by the General Rules of Interpretation (GRI's). GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Merchandise that cannot be classified in accordance with GRI 1 is to be classified in accordance with subsequent GRI's taken in order. The Explanatory Notes to the Harmonized CommodityDescription and Coding System (EN's), which represent the official interpretation of the tariff at the international level, facilitate classification under the HTSUSA by offering guidance in understanding the scope of the headings and GRI's.

Auto detail towels are used as cleaning towels for automobiles in the application and removal of wax, shampoo, cleaners, or other liquids. These towels are primarily used in "auto detail" shops which provide services for exterior and interior care of motor vehicles. They are also sold to consumers at car washes, auto supply stores, and department stores. In accordance with GRI 1, such towels are provided for under subheading 6307.10.1000, HTSUSA, as "Dustcloths, mop cloths and polishing cloths, of cotton... ." The EN's to heading 6307, state that the heading includes, "Floor-cloths, dish-cloths, dusting cloths and similar cleaning cloths ... ." However, the EN's additionally note that heading 6307 covers only those made up articles of any textile material which are not included more specifically in other headings of Section XI or elsewhere in the Nomenclature.

In this case, the towels have dimensions and features which would also render them subject to use as "hand towels" or "dish towels" which are classifiable under 6302.60.00, HTSUSA, as "Toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton; Towels ... ." The Textile Category Guidelines (CIE 13/88 of November 23, 1988) state that dish towels and hand towels fall within the same size range, 24 to 32 inches long and 15 to 18 inches wide. Additionally, the towels have dimensions and features very similar to a "bar mop" towel which is classifiable under 6307.10.2020, HTSUSA, as "Bar mops" of cotton terry fabric measuring 46 to 57 centimeters in length and 38 to 43 centimeters in width (approximately 18 to 22 inches in length and 15 to 17 inches in width).

Inasmuch as the submitted towels (measuring approximately 14 x 24, 14 x 26, 14 x 28 inches) are so close in size to "hand/dish towels" and "bar mop" towels, we requested additional documentation to verify the intended use as "auto detail" towels. You have provided several trade magazines entitled, Professional Carwashing & Detailing, highlighting the advertisements for the subject towels
which clearly specify their use as "auto detail" towels for washing, drying, cleaning, and polishing in the auto industry. In addition, the packaging in which the towels will be sold, specifically identifies the product as auto detailing towels.

Based on the evidence provided, it is our determination that the subject towels are imported for use as "auto detail" towels and are properly classifiable under subheading 6307.10, HTSUSA, as "Floorcloths, dishcloths, dusters and similar cleaning cloths."

HOLDING:

The subject towels are classifiable under subheading 6307.10.1000, HTSUSA, which is the provision for "Other made up articles, including dress patterns: Floorcloths, dishcloths, dusters and similar cleaning cloths: Dustcloths, mop cloths and polishing cloths, of cotton." This provision is dutiable under the general colum one rate at 4.5 percent ad valorem. The textile restraint category is 369.

The designated textile and apparel category may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. Since part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes, to obtain the most current information available, we suggest that you check, close to the time of shipment, The Status Report on Current Import Quotas (Restraint Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.

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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