The tariff classification of an exfoliating cloth from China

N362359
July 7, 2026
CLA-2-63:OT:RR:N2:349
CATEGORY: Classification
TARIFF NO.: 6302.91.0060
Ms. Amy Rojas Rojamy LLC 204 Courtney Chase Drive St. Augustine, FL 32092 RE: The tariff classification of an exfoliating cloth from China Dear Ms. Rojas: In your letter dated June 15, 2026, you requested a tariff classification ruling for an exfoliating cloth. A sample of the product was provided to this office and will be retained for training purposes. The imported item is an unfinished facial exfoliating cloth composed of two layers of 100 percent cotton cheesecloth fabric. The two layers of fabric are treated with tannin pre-mordant, cut into 6 x 6-inch squares, and sewn together with an overlock stitch. After importation, a charcoal dye is applied, and a decorative zigzag border stitch is sewn around the edges. The finished product is sold as a facial exfoliating cloth under the Romjay™ brand. The “So Polished Facial Cloth Refill,” SKU R-LE002, is sold at retail with two cloths. The “So Polished Facial Cloth Kit,” SKU K-LE001, is sold at retail with two cloths and a magnetic hanger. Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRI’s). GRI 2(a) provides that any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also include a reference to that article complete or finished (or failing to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled. The Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System represent the official interpretation of the Customs Cooperation Council on the scope of each heading; although neither binding upon the contracting parties to the Harmonized System Convention nor considered to be dispositive interpretations, they may be consulted on the proper scope of the heading. In your letter, you suggest the exfoliating cloth is classified under subheading 9616.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Scent sprayers and similar toilet sprayers, and mounts and heads therefor; powder puffs and pads for the application of cosmetics or toilet

preparations.” We disagree because they are not of the same class or kind as the exemplars listed in Explanatory Notes (ENs) 9616. Therefore, classification in subheading 9616.20.0000 is precluded. Alternatively, you suggest that the exfoliating cloth should be classified under subheading 6307.90.9889, HTSUS; however, the suggested classification is no longer valid as of midnight June 30, 2020. The current classification is 6307.90.9891, HTSUS; however, for an article to be considered a made-up article of textile under subheading 6307.90.9891, HTSUS, there cannot be a more specific heading that also provides for the classification of the article. As the article is more specifically provided for in Heading 6302, HTSUS, it will be classified therein. Lastly, you suggest classification of the exfoliating cloth under subheading 6302.90.0010, HTSUS, which is also not a valid subheading. We assume you intended to indicate 6302.91.0060, HTSUS, which provides for “Bed linen, table linen, toilet linen and kitchen linen: Other: Of cotton…Other: Other.” We agree. The duty rate will be 9.2 percent ad valorem. While a marking ruling has not been requested, we note that the submitted sample marked “Made in USA with imported fabric from China” and packaging marked “Made with Love in USA Imported fabric from China” are not legally marked. The imported item is not fabric but an unfinished made-up cloth. Further, based on the information provided, the general rules of origin set forth in paragraphs (c)(1) through (5) of section 102.21 of the Customs Regulations do not support a finding of U.S. origin. See 19 CFR 102.21(c). Based on the information provided, origin for the facial exfoliating cloth, both unfinished and finished, is conferred in China. Section 134.11 of the Customs Regulations (19 CFR 134.11) states, “Unless excepted by law, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), requires that every article of foreign origin (or its container) imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit, in such manner as to indicate to an ultimate purchaser in the United States the English name of the country of origin of the article, at the time of importation into the Customs territory of the United States.” Section 134.26 of the Customs Regulations (19 CFR 134.26) states, “If an article subject to these requirements is intended to be repacked in retail containers (e.g., blister packs) after its release from Customs custody, or if the Center director has reason to believe such article will be repacked after its release, the importer shall certify to the Center director that: (1) If the importer does the repacking, he shall not obscure or conceal the country of origin marking appearing on the article, or else the new container shall be marked to indicate the country of origin of the article in accordance with the requirements of this part.” Please ensure that your imported cloths and retail packaging used to package the cloths in the United States are legally marked. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at

https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Kim Wachtel at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division