The following proposed revocations of U.S. Customs and Border Protection rulings are included in the Aug. 5, 2020, Customs Bulletin and Decisions. Comments on these proposed changes are due by Sept. 4.

For more information on how to seek or utilize classification and other rulings, please contact Deb Stern at (305) 894-1007.

Hand Sanitizer

CBP is proposing to reclassify various types of hand sanitizer as disinfectants and similar products under HTSUS 3808.94.50 (5 percent duty) rather than as other chemical preparations under HTSUS 3824.99.92 (5 percent duty). Rulings N311037, N304365, N303248, N242763, N233860, N032988, and L89057 would be revoked to reflect this change.

CBP explains that alcohol in sufficient concentration destroys or irreversibly inactivates undesirable bacteria, viruses, or other microorganisms and that all of the hand sanitizers at issue contain significant amounts of alcohol, usually ethyl alcohol. Additionally, in accordance with Section VI note 2, disinfectants put up for retail sale are to only be classified in heading 3808. While the Explanatory Notes states that disinfectants are used “generally for” disinfecting hard surfaces such as table tops or operating tables, this guidance does not exclude disinfectants formulated for use on the hands.

Disposable Bibs and Changing Pads

CBP is proposing to reclassify disposable bibs, changing pads, and potty toppers as apparel or other articles of paper of a kind used for household or sanitary purposes under HTSUS 4818.50.00 or or 4818.90.00 (both duty-free) rather than as diapers and diaper liners and similar articles under HTSUS 9619.00.1100 (duty-free). CBP explains that articles of heading 9619 absorb bodily fluids and fit snugly to the human body, neither of which is true for the articles at issue. Rulings NY N243080 and NY N256859 would be revoked to reflect this change.

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Deborah B. Stern
Partner, Advisory Committee

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