HQ 085183: Beach Blankets

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                            HQ 085183

                         October 5, 1989


CLA-2  CO:R:C:G  085183  JBW

CATEGORY: Classification

TARIFF NO.:  6302.60.0020

Mr. Richard H. Simpson
W. G. Carroll & Co., Inc.
185 East Bay Street, Suite 204
P. O. Box 685
Charleston, S.C. 29402

RE:  Beach Blankets

Dear Mr. Simpson:

          Your letter of June 26, 1989, on behalf of Terrimondo,
Inc., addressed to our Charleston office, has been referred to
this office for reply concerning the classification of beach
blankets under the Harmonized Tariff Schedule of the United
States Annotated (HTSUSA).

FACTS:

          Two samples of the goods to be imported were submitted
for classification.  Both samples are constructed of cotton woven
fabric with finished edges.  One sample is an oversized towel
measuring 158 by 178 centimeters with a terry pile on one side
and a cut pile on the opposite side.  The other sample is an
oversized towel measuring 140 by 178 centimeters with a terry
pile construction on both sides.  The packaging of the product
describes it as a "beach blanket."

ISSUE:

          What is the classification of cotton terry fabric with
finished edges and with dimensions exceeding 140 by 178
centimeters?

LAW AND ANALYSIS:

          The General Rules of Interpretation (GRI's) set forth
the legal framework in which merchandise is to be classified
under the HTSUSA.  GRI 1 requires that classification be
determined first according to the terms of the headings of the
tariff and any relative section or chapter notes and, unless
otherwise required, according to the remaining GRI's.

          Heading 6302, HTSUSA, provides for "[t]oilet and
kitchen linen, of terry toweling or similar terry fabrics, of
cotton."  The Explanatory Notes, which provide the official
interpretation of the HTSUSA at the international level, include
beach towels as toilet linen.  Beach towels normally have
dimensions ranging from 76 by 152 centimeters to 92 by 182
centimeters, but may be larger.  The merchandise under
consideration is of towel construction and fits the description
of a beach towel.  The merchandise is consequently classified
under subheading 6302.60.0020, HTSUSA.

          The items under consideration are described as "beach
blankets."  The Explanatory Notes to Heading 6301, HTSUSA, state
that blankets are "generally of thick, heavy-texture for
protection against the cold."  The beach blankets are not
designed for protection against the cold and consequently are not
blankets for tariff purposes.

HOLDING:

          The "beach blankets" are classified under subheading
6302.60.0020, HTSUSA, as toilet and kitchen linen, of terry
toweling or similar terry fabrics, of cotton, towels, other.  The
applicable duty is 10.3 percent ad valorem, and the textile
category is 363.

          The designated textile and apparel category may be
subdivided into parts.  If so, visa and quota requirements
applicable to the subject merchandise may be affected.  Since
part categories are the result of international bilateral
agreements that are subject to frequent renegotiations and
changes, to obtain the most current information available, we
suggest that you check, close to the time of shipment, the Status
Report On Current Import Quotas (Restraint Levels), an internal
issuance of the United States Customs Service, which is available
for inspection at your local Customs office.

          Due to the changeable nature of the statistical
annotation (the ninth and tenth digits of the classification) and
the restraint (quota/visa) categories, you should contact your
local Customs office prior to importation of this merchandise to
determine the current status of any import restraints or
requirements.

                              Sincerely,



                              John Durant, Director
                              Commercial Rulings Division