The tariff classification of Medical Prep Mats from Malaysia

N293823 May 8, 2018 CLA-2-48:OT:RR:NC:4:434 CATEGORY: Classification TARIFF NO.: 4818.90.0000 Ms. Maureen Ford Ansell Healthcare Products 111 Wood Ave. Suite 210 Iselin, NJ 08830 RE: The tariff classification of Medical Prep Mats from Malaysia Dear Ms. Ford: In your letter, dated January 19, 2018, you requested a classification ruling. A sample of the product was submitted for our review and was consumed during laboratory analysis. We apologize for the delay in issuing a ruling incurred by the testing. The “BioClean ChemPrep Prep Mat” is designed for placement on a workbench in a medical or laboratory setting to protect technicians, nurses and pharmacists when handling or administering chemotherapy drugs. The mats come in two sizes, 40 cm x 25 cm and 56 cm x 40 cm. Each mat is constructed of a top layer of polyethylene apertured film, which allows liquids to pass through to the middle layer; a middle layer of absorbent air-laid paper; and a bottom layer of polyethylene plastic film, which acts as a moisture barrier. Per the laboratory analysis, the top sheet comprises 11.3% of the total, by weight; the middle layer of paper comprises 71.4%, and the bottom polyethylene layer comprises 17.3%. General Rule of Interpretation ("GRI") 3 (b) of the Harmonized Tariff Schedule of the United States (HTSUS) states as follows: (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. In accordance with the Explanatory Notes (ENs) for GRI 3(b), the essential character of an item may be determined by the nature of the material or component, its bulk, quantity, weight, or value, or by the role of a constituent material in relation to the use of the goods. The inner layer of absorbent paper is critical to the function of the mat. Further, the paper predominates by weight and bulk. It is the opinion of this office that the paper provides the essential character of the mats. Therefore, the applicable subheading for the prep mats will be 4818.90.0000, HTSUS, which provides for Toilet paper and similar paper, cellulose wadding or webs of cellulose fibers, of a kind used for household or sanitary purposes, in rolls of a width not exceeding 36 cm, or cut to size or shape; handkerchiefs, cleansing tissues, towels, tablecloths, table napkins, bed sheets and similar household, sanitary or hospital articles, articles of apparel and clothing accessories, of paper pulp, paper, cellulose wadding or webs of cellulose fibers: Other. The rate of duty will be free. 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 on the World Wide Web at https://hts.usitc.gov/current. 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 Charlene Miller at charlene.miller@dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division