The tariff classification of a polyester needleloom felt fabric
Issued March 2, 2016 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 5602.10.9090
Headings: 5602
Product description
Lydall Part Number PE/BLK - 40.5/DD is a thick grey fibrous fabric, with a thin layer of black material on one side. U.S. Customs and Border Protection (CBP) laboratory analysis determined that this product is a needleloom felt consisting of more than three polyester staple fiber webs bonded to a polyester staple fiber base. The layers have been bonded together by the needle punching method, involving needling webs of staple textile fibers through a base of textile fabric. The sample does not have an application of any rubber/plastic or natural material on its surfaces or within the web and fibers. Your correspondence indicates that this needleloom felt fabric is to be used in the automotive industry as sound dampening material in wheels, trunks and door panels. The fabric will be imported in rolls of approximately 80 inches (2 meters) in width and 100 yards in length and will weigh approximately 1300 g/m2. In your submission, you suggest classification as a felt of subheading 5602.10.9090, or alternatively, as a floor covering under subheading 5704.90.0090, Harmonized Tariff Schedule of the United States (HTSUS). However, the latter provision is for carpets and other textile floor coverings, and the instant product is intended to be used as a sound dampening material in wheel wells, trunks and door panels.
CBP rationale
The applicable subheading for the fabric identified as Lydall Part Number PE/BLK - 40.5/DD will be 5602.10.9090, HTSUS, which provides for felt, whether or not impregnated, coated, covered or laminated: needleloom felt and stitch-bonded fiber fabrics: other, other.
Full text
N263391 March 2, 2016 CLA-2-56:OT:RR:NC:N3:350 CATEGORY: Classification TARIFF NO.: 5602.10.9090 Mr. Damon V. Pike The Pike Law Firm, P.D. 246 Sycamore Street Suite #215 Decatur, Georgia 30030-3434 RE: The tariff classification of a polyester needleloom felt fabric Dear Mr. Pike: In your letter dated March 23, 2015, you requested a tariff classification ruling on behalf of your client Lydall Performance Materials, Inc. A sample was submitted with your ruling request. Lydall Part Number PE/BLK - 40.5/DD is a thick grey fibrous fabric, with a thin layer of black material on one side. U.S. Customs and Border Protection (CBP) laboratory analysis determined that this product is a needleloom felt consisting of more than three polyester staple fiber webs bonded to a polyester staple fiber base. The layers have been bonded together by the needle punching method, involving needling webs of staple textile fibers through a base of textile fabric. The sample does not have an application of any rubber/plastic or natural material on its surfaces or within the web and fibers. Your correspondence indicates that this needleloom felt fabric is to be used in the automotive industry as sound dampening material in wheels, trunks and door panels. The fabric will be imported in rolls of approximately 80 inches (2 meters) in width and 100 yards in length and will weigh approximately 1300 g/m2. In your submission, you suggest classification as a felt of subheading 5602.10.9090, or alternatively, as a floor covering under subheading 5704.90.0090, Harmonized Tariff Schedule of the United States (HTSUS). However, the latter provision is for carpets and other textile floor coverings, and the instant product is intended to be used as a sound dampening material in wheel wells, trunks and door panels. The applicable subheading for the fabric identified as Lydall Part Number PE/BLK - 40.5/DD will be 5602.10.9090, HTSUS, which provides for felt, whether or not impregnated, coated, covered or laminated: needleloom felt and stitch-bonded fiber fabrics: other, other. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Maribeth Dunajski at cbp.dhs.gov. Sincerely, Deborah C. Marinucci Acting Director National Commodity Specialist Division
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