enterRoutes 1 and 9 South, Room 200Newark, NY 07114

HQ 961144 November 23, 1999 CLA-2 RR:CR:TE 961144 jb CATEGORY: Classification Port Director U.S. Customs Service Hemisphere Center Routes 1 and 9 South, Room 200 Newark, NY 07114 Dear Port Director: This letter concerns a protest (1001-97-105274) and an application for further review filed by Graham & James LLP on behalf of their client, Best Manufacturing Inc., regarding the tariff classification of cotton terry towels under the Harmonized Tariff Schedule of the United States (HTSUS). The merchandise at issue consists of 100 percent cotton bleached terry towels ranging in size from approximately 15 inches to 18 inches in width by 17 inches to 20 inches in length, which have been hemmed on all four sides. The towels are primarily sold by the protestant to commercial laundries which rent the articles to such U.S. institutional users as restaurants and hotels for use in cleaning and mopping-up spills in food and beverage preparation and service areas. The classification of identical merchandise was addressed in Headquarters Ruling Letter (HQ) 961243, dated July 7, 1999. Therein it was determined that the subject merchandise is properly classified in subheading 6307.10.1000, HTSUSA, which provides for, other made up articles, including dress patterns: floorcloths, dishcloths, dusters and similar cleaning cloths: dustcloths, mop cloths and polishing cloths, of cotton. Attached you will find HQ 961243 for your reference. As the subject merchandise is identical to the merchandise addressed in HQ 961243, the subject merchandise should be classified accordingly, and the protest should be granted in full.  Should you have any questions or require additional information, please do not hesitate to call us at such time. Sincerely, John Durant, Director Commercial Rulings Division