H341540

H341540 September 5, 2025 OT:RR:CTF:FTM H341540 MJD CATEGORY: Classification TARIFF NO.: 6301.40.00 Mr. Casey Phillips Pereira Cypress Medical Products 9954 Mayland Drive Richmond, Virginia 23233 RE: Tariff Classification of a Stretcher Blanket Dear Mr. Pereira, This letter is in response to your request, on behalf of Cypress Medical Products (“Requestor”), dated June 26, 2024, for a binding ruling regarding the tariff classification of a stretcher blanket under the Harmonized Tariff Schedule of the United States (“HTSUS”). The request is a resubmission of a previous ruling request that pertained to the stretcher blanket subject to this ruling and that was returned for additional information. This request was forwarded by the National Commodity Specialist Division to our office for a response. In arriving at our determination set forth below, we considered the information submitted in the ruling request, the sample we received, and the additional information submitted via e-mail. The Requestor asked that certain information submitted in connection with this ruling be treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. The information contained within brackets will not be released to the public and will be withheld from published versions of this ruling. FACTS: The subject merchandise, item number 16-10224, is a gray disposable stretcher blanket constructed of a single layer of 100 percent polyester nonwoven fabric. The blanket measures 40 x 80 inches. The blanket is used to keep patients covered and comfortable during transportation 1 or treatment, and can also be used in emergency situations. The following is a description of the construction process of the nonwoven material that makes up the stretcher blanket: First, polyester fibers are extracted from bales and weighed to measure predetermined percentages, as required. Next, the fibers are transferred to an opener machine to loosen them. Subsequently, the fibers are mixed using a blender machine. Afterward, a carding machine is utilized to form the fibers into webs. Once the web formation is complete, the fibers are punched three times with needles to interlock them and strengthen the fabric. Following this, the surface of the material is smoothed out using hot ironing rollers. Finally, the fabric is cut to the desired width using a slitting knife, and the material is wound to the desired length using a winder. After the fabric is formed, it is taken to a separate assembly line where the edges of the blanket are finished using an ultrasonic sewing technique. According to the Requestor, as the fabric passes under the ultrasonic sewing machine’s horn, ultrasonic vibration causes the materials to heat up and fuse together, thereby finishing the edges without using any additional glue or heat. There are two suppliers who manufacture the stretcher blanket, [***] and [***]. The manufacturers have different production techniques. The production process for the stretcher blanket at each facility is the following: [***]: - Step 1. Textile manufacturing - Step 2. Ultrasonic sealing on all four edges - Step 3. Folding - Step 4. Machine cutting of fabric to size - Step 5. Sewing of label onto blanket - Step 6. Folding - Step 7. Packing of blanket into bag - Step 8. Compressing the bag - Step 9. Packing into carton [***]: - Step 1. Textile fabric purchased in rolls from supplier - Step 2. Machine cutting of fabric to size - Step 3. Ultrasonic sealing on all four edges - Step 4. Manual sewing of label onto blanket - Step 5. Folding - Step 6. Packing of blanket into bag - Step 7. Compressing the bag - Step 8. Packing into carton As part of the submission, the Requestor submitted a sample of the stretcher blanket. The Requestor also included a video of the production process of the stretcher blanket at both 2 facilities, photos of the production equipment at the [***], and a material specification for the [***]. ISSUE: What is the tariff classification of the stretcher blanket? LAW AND ANALYSIS: Classification decisions under the HTSUS are made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. The 2025 HTSUS provisions under consideration are as follows: 5603 Nonwovens, whether or not impregnated, coated, covered or laminated: 6301 Blankets and traveling rugs: * * * Note 7 to Section XI, HTSUS, provides as follows: For the purposes of this section, the expression “made up” means: (a) Cut otherwise than into squares or rectangles; (b) Produced in the finished state, ready for use (or merely needing separation by cutting dividing threads) without sewing or other working (for example, certain dusters, towels, tablecloths, scarf squares, blankets); (c) Cut to size and with at least one heat-sealed edge with a visibly tapered or compressed border and the other edges treated as described in any other subparagraph of this Note, but excluding fabrics the cut edges of which have been prevented from unravelling by hot cutting or by other simple means; (d) Hemmed or with rolled edges, or with a knotted fringe at any of the edges, but excluding fabrics the cut edges of which have been prevented from unraveling by whipping or by other simple means; (e) Cut to size and having undergone a process of drawn thread work; 3 (f) Assembled by sewing, gumming or otherwise (other than piece goods consisting of two or more lengths of identical material joined end to end and piece goods composed of two or more textiles assembled in layers, whether or not padded); or (g) Knitted or crocheted to shape, whether presented as separate items or in the form of a number of items in the length. * * * In addition, in interpreting the HTSUS, the Explanatory Notes (“ENs”) of the Harmonized Commodity Description and Coding System may be utilized. The ENs to the Harmonized Commodity Description and Coding System represent the official interpretation of the tariff at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The EN to heading 63.01 states in relevant part: Blankets and travelling rugs are usually made of wool, animal hair, cotton or man-made fibres, frequently with a raised pile surface, and generally of thick heavy-texture material for protection against the cold. The heading also covers rugs and blankets for cots or prams. Travelling rugs usually have fringes (generally formed by projecting warp or weft threads), but the edges of blankets are normally preserved by blanket stitching or binding. The heading includes fabrics in the piece which, by the simple process of cutting along defined lines indicated by the absence of weft threads, may be converted into separate articles having the character of finished blankets or travelling rugs. Electrically heated blankets are also included in the heading. * * * U.S. Customs and Border Protection’s (“CBP”) has previously considered a similar stretcher blanket. New York Ruling Letter (“NY”) N334912, dated January 26, 2024, was issued to the Requestor for the same product, a gray stretcher blanket, item number 16-10224. However, the stretcher blanket in NY N334912 featured unfinished/unhemmed edges that did not go through an ultrasonic sewing machine like the blanket at issue here. The stretcher blanket in NY N334912 was classified in heading 5603, HTSUS, and specifically in subheading 5603.93.0

Classification decisions under the HTSUS are made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. The 2025 HTSUS provisions under consideration are as follows: 5603 Nonwovens, whether or not impregnated, coated, covered or laminated: 6301 Blankets and traveling rugs: * * * Note 7 to Section XI, HTSUS, provides as follows: For the purposes of this section, the expression “made up” means: (a) Cut otherwise than into squares or rectangles; (b) Produced in the finished state, ready for use (or merely needing separation by cutting dividing threads) without sewing or other working (for example, certain dusters, towels, tablecloths, scarf squares, blankets); (c) Cut to size and with at least one heat-sealed edge with a visibly tapered or compressed border and the other edges treated as described in any other subparagraph of this Note, but excluding fabrics the cut edges of which have been prevented from unravelling by hot cutting or by other simple means; (d) Hemmed or with rolled edges, or with a knotted fringe at any of the edges, but excluding fabrics the cut edges of which have been prevented from unraveling by whipping or by other simple means; (e) Cut to size and having undergone a process of drawn thread work; 3 

(f) Assembled by sewing, gumming or otherwise (other than piece goods consisting of two or more lengths of identical material joined end to end and piece goods composed of two or more textiles assembled in layers, whether or not padded); or (g) Knitted or crocheted to shape, whether presented as separate items or in the form of a number of items in the length. * * * In ad