NY N342179: The tariff classification of yarns from Turkey

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.

N342179  
July 8, 2025
  CLA-2-54:OT:RR:NC:N3:351  
CATEGORY: Classification  
TARIFF NO.: 5404.90.0000; 5607.49.1500; 9903.01.25
  Ms. Kristina Barry  GDLSK LLP  599 Lexington Avenue, Floor 36  New York, NY 10022  RE:  The tariff classification of yarns from Turkey  Dear Ms. Barry:  In your letter dated August 20, 2024, you requested a tariff classification ruling on behalf of your client,  Cosmic International Yarns LLC. Samples of five yarns were provided and sent to the U.S. Customs and  Border Protection (“CBP”) laboratory for analysis. The samples will be retained for training purposes.  Item 1 is described as a fibrillated yarn. You state the fibrillated yarn will be composed of either 100 percent  polypropylene fibrillated filament strip or 100 percent polyethylene fibrillated filament strip. It may have a  linear density of either 7,500 or 2,200 decitex, depending on the color. The yarn does not exceed 5  millimeters (mm) in width.  You provided two samples of the fibrillated yarn. According to CBP’s laboratory analysis, sample 1 of the  fibrillated yarn, labeled “Fibrillated 2200 decitex PP,” is a folded and twisted fibrillated filament strip  composed wholly of polypropylene fibers. The yarn has an average apparent width of 2.2 mm and is in a  S-twist configuration with an average of 1.3 twists per meter. The weight of the yarn with support is 590  grams and the yarn has a linear density of 2207 decitex.  According to CBP’s laboratory analysis, sample 2 of the fibrillated yarn, labeled “Fibrillated 7500 Dtex PP,”  is a folded and twisted fibrillated filament strip composed wholly of polypropylene. The yarn has an average  apparent width of 1.5 mm and is in a S-twist configuration with an average of 18 twists per meter. The  weight of the yarn with support is 1296.4 grams and the yarn has a linear density of 6856.7 decitex.  Item 2 is described as “monofilament straight yarn.” You state the yarn is a 6-ply 100 percent polyethylene  filament yarn measuring 13,300 decitex.  According to CBP’s laboratory analysis, the sample of the monofilament straight yarn, labeled  “monofilament straight 13,300/6 DTEX PE” is a 6-ply yarn composed of continuous polyethylene strips with 

an average width of 1.2 mm per strip and an approximate width of 2.0 mm for the entire yarn. The yarn has a  Z twist configuration with an average of 43 turns per meter. The weight of the yarn with support is 972.7  grams and the yarn has a linear density of 12,664.7 decitex. The yarn is neither textured nor elastomeric.  Item 3 is described “monofilament textured curly yarn.” You state the yarn is an 8-ply monofilament yarn  composed of either polypropylene or polyethylene and has a linear density of 5,555 decitex.  According to CBP’s laboratory analysis, the sample of the monofilament textured curly yarn, labeled  “Monofilament Curly 5555/8 decitex PP,” is a 97 percent polypropylene and 3 percent polyester yarn  composed of seven polypropylene strips and one multifilament polyester textured yarn twisted together. The  width of each strip is approximately 0.7 mm. The yarn has a final Z twist configuration with 20 turns per  meter. The weight of the yarn with support is 405.7 grams and the yarn has a linear density of 5601 decitex.  The yarn is not considered elastomeric.  Item 4 is described as a “monofilament combination yarn” in which 8-plies of straight monofilament yarns  are twisted together with 8-plies of curly yarns. You state the 16-ply yarn is composed from either  polypropylene or polyethylene and has a linear density of 10,300 decitex.  According to CBP’s laboratory analysis, the sample of the combination yarn, labeled “Combination PE  6800/8 Straight PP 3500/8 Curly 10300/16” is a 16-ply yarn consisting of eight single polyethylene strips and  eight single polypropylene strips twisted together. The yarn is 66.1 percent polyethylene and 33.9 percent  polypropylene. The average width of each strip is approximately 1 mm and an approximate width of 2.6 mm  for the entire yarn. The yarn has a S twist configuration with 21 turns per meter. The weight of the yarn with  support is 212.5 grams and the yarn has a linear density of 10,813 decitex. The yarn is not considered  textured or elastomeric.  You have suggested that the 2200 decitex and 7500 decitex fibrillated yarns should be classified under  heading 5404.90.0000, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for  “Synthetic monofilament of 67 decitex or more and of which no cross-sectional dimension exceeds 1mm;  strip and the like (for example, artificial straw) of synthetic textile materials of an apparent width not  exceeding 5 mm: Other.” We agree. The rate of duty will be free.  You have suggested that the 13300/6 decitex monofilament straight yarn and 10300/16 decitex monofilament  combination yarn should be classified under 5607.49.2500, HTSUS, which provides for “Twine, cordage,  ropes and cables, whether or not plaited or braided and whether or not impregnated, coated, covered or  sheathed with rubber or plastics: Of polyethylene or polypropylene: Other: Other, not braided or plaited:  Other.” The rate of duty is 9.8 c/kg + 5.3 percent ad valorem. We disagree. The approximate width of the  13300/6 decitex monofilament straight yarn is 2.0 mm. The approximate width of the 10300/16 decitex  monofilament textured curly yarn is 2.6 mm.  The applicable subheading for the 13300/6 decitex monofilament straight yarn and 10300/16 decitex  monofilament combination yarn will be 5607.49.1500, HTSUS, which provides for “Twine, cordage, rope  and cables, whether or not plaited or braided and whether or not impregnated, coated, covered or sheathed  with rubber or plastics: Of polyethylene or polypropylene: Other: Other, not braided or plaited: Measuring  less than 4.8 mm in diameter.” The rate of duty will be 7 percent ad valorem.  You have suggested that the 5555/8 decitex monofilament textured curly yarn if composed from  polypropylene should be classified under 5404.12.1000, HTSUS, which provides for “Synthetic  monofilament of 67 decitex or more and of which no cross-sectional dimension exceeds 1mm; strip and the  like (for example, artificial straw) of synthetic textile materials of an apparent width not exceeding 5 mm:  Other, of polypropylene: Not over 254 mm in length.” We disagree. You have also suggested that the 5555/8  decitex monofilament textured curly yarn if composed from polyethylene should be classified under  5404.19.8080, HTSUS, which provides for “Synthetic monofilament of 67 decitex or more and of which no 

cross-sectional dimension exceeds 1mm; strip and the like (for example, artificial straw) of synthetic textile  materials of an apparent width not exceeding 5 mm: Other: Other: Other.” We disagree. Though a sample of  the 5555/8 polyethylene yarn was not provided, we assume you provided the 5555/8 polypropylene yarn as a  representative sample of the construction of both yarns. The 5555/8 polypropylene yarn is constructed of  seven polypropylene strips and a multifilament polyester textured yarn twisted together. As the yarn is  constructed of strip and not monofilaments the yarn cannot be classified under 5404.12.1000 if composed of  polypropylene or 5404.19.8080 is composed of polyethylene.  The applicable subheading for the 5555/8 decitex monofilament textured curly yarn of either polypropylene  or polyethylene will be under heading 5404.90.0000, HTSUS, which provides for “Synthetic monofilament  of 67 decitex or more and of which no cross-sectional dimension exceeds 1mm; strip and the like (for  example, artificial straw) of synthetic textile materials of an apparent width not exceeding 5 mm: Other.” The  rate of duty will be free.  Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must  be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the  Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries  will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the  Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to subheadings  5404.90.0000 and 5607.49.1500, HTSUS, listed above.  The tariffs and additional 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/.  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 Kristine Dodge at kristine.dodge@cbp.dhs.gov.  
Sincerely,
  (for)  James Forkan  Acting Director  National Commodity Specialist Division