N354952

N354952 October 29, 2025 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 6307.90.9891; 9903.01.24; 9903.01.25; 9903.88.15 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 kristine.dodge@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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 kristine.dodge@cbp.dhs.gov. 
Sincerely,
 (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division