The tariff classification of carboxymethyl cellulose tow from the United Kingdom

N317002 May 6, 2021 CLA-2-55:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 5504.90.0000 Mr. Michael Murray DeSales Trading Company, Inc. 609 Tucker Street Burlington, NC 27216 RE: The tariff classification of carboxymethyl cellulose tow from the United Kingdom Dear Mr. Murray: In your letter dated January 18, 2021, you requested a tariff classification ruling. A sample of the carboxymethyl cellulose (CMC) tow was provided and sent for laboratory analysis. The sample will be retained for reference purposes. You state the sample submitted is 100 percent CMC tow. The tow is produced from staple fibers with random lengths of 1 to 3 meters. The tow is packaged in a 7 pound bag and shipped to the United States. The tow is intended to produce wound care fabric dressings. According to U.S. Customs and Border Protection (“CBP”) laboratory analysis, the CMC tow is wholly composed of artificial man-made staple fibers, not carded, combed or otherwise processed for spinning. The fibers have an average apparent length of four centimeters. The sample fibers are not of acetate or rayon composition. You have suggested that the CMC tow should be classified under subheading 3005.90.50, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “wadding, gauze, bandages and similar articles (for example, dressings, adhesive plasters, poultices), impregnated or coated with pharmaceutical substances or put up in forms or packings for retail sale for medical, surgical, dental, or veterinary purposes: Other: Other: Other.” We disagree. The CMC tow is not a finished product put up for retail sale. The applicable subheading for the CMC tow will be 5504.90.0000, HTSUS, which provides for “artificial staple fibers, not carded, combed or otherwise processed for spinning: Other.” The rate of duty will be 4.3 percent ad valorem. 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 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, please contact National Import Specialist Kristine Dodge via email at Kristine.Dodge@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division