NCS/ARS/CL/10442

You have applied for an Advance Ruling on the tariff classification of MOLFIX Wet Baby Wipes for Newborn with Isotonic Water, packed 50 pieces per pack and imported in cartons.

PRODUCT ANALYSIS

Based on the Technical Data Sheet submitted, the product is a pre-moistened, disposable wet wipe specifically designed for the gentle cleansing and personal hygiene of newborn babies. The product is intended for direct application to the skin and is described as providing gentle and effective cleansing while helping to moisturize and condition the skin.

The wipes consist of a nonwoven spun lace substrate impregnated with a water-based liquid formulation.  The nonwoven substrate is composed of cotton, viscose and polyester fibres, while the impregnating liquid is principally purified water containing preservatives and other functional ingredients.

The product is presented in a finished and ready-to-use form, requiring no further processing or preparation before use.

TECHNICAL SPECIFICATIONS

LIQUID COMPOSITION

The impregnating liquid is stated to contain Aqua (purified water), Phenoxyethanol, Sodium chloride, Tetrasodium EDTA, Benzoic acid, Dehydroacetic acid and Triethanolamine.

The formulation is principally water-based, with the other ingredients serving functions including preservation, pH adjustment, chelation and product stability.

PRODUCT CHARACTERISTICS AND FUNCTION

Spunlace is a type of nonwoven fabric that is made from fibers that are bonded together by mechanical, thermal, or chemical means. 

The nonwoven spunlace substrate provides the physical structure of the wipe and is suitable for gentle cleansing of the skin. The substrate comprises cotton, viscose and polyester fibres and has a grammage of 47 g/m². The hydro-embossed surface provides the required texture and facilitates its cleansing function.

The water-based impregnating formulation keeps the substrate moist and ready for use and provides the medium through which the wipe performs its cleansing and conditioning function. The formulation also contains preservatives and other ingredients necessary for maintaining the stability and quality of the product.

Although the product is impregnated with a liquid preparation, the wipe retains the essential characteristics of a nonwoven textile material. It is presented as a finished disposable article principally consisting of a nonwoven substrate, with the liquid serving to render the article suitable for its intended cleansing function.

TARIFF CLASSIFICATION

Based on the above, and in line with the provision of Note 11 to Section XI, it defined the expression “impregnated” to include “dipped”.

Furthermore, Note 15 to Section XI, state that, textiles, garments and other textile articles, incorporating chemical, mechanical or electronic components for additional functionality, whether incorporated as built-in components or within the fibre or fabric, are classified in their respective headings in Section XI provided that they retain the essential character of the goods of Section XI.

The product consists principally of a nonwoven textile substrate made from cotton, viscose and polyester fibres. The substrate has a grammage of 47 g/m² and is impregnated with a purified water-based formulation. The impregnating liquid performs an ancillary function by keeping the textile substrate moist and suitable for its intended use as a cleansing wipe, while the product retains the essential character of a nonwoven textile material.

Accordingly, the product falls under heading 5603 – Nonwoven, whether or not impregnated, coated, covered or laminated, and properly classified in tariff subheading 5603.12.00.00 - Nonwoven, whether or not impregnated, coated, covered or laminated, Of man-made filaments: Weighing more than 25 g/m² but not more than 70 g/m², at 20% rate of duty and 7.5% VAT in line with ECOWAS Common External Tariff (CET) 2022 – 2027.

LEGAL JUSTIFICATION

• GIR 1 & 6
• Note 11 and 15 to section XI