Proper Rate of Advance Sales Tax on Towelette Rolls (Non-Woven Fabric) Imported by Sterling Products International, Inc.

March 17, 1987 BIR RULING NO. 075-87 163 000-00 075-87 S i r : This refers to your letter dated October 17, 1985 requesting a ruling on the proper rate of advance sales tax on towelette rolls (non-woven fabric) imported by Sterling Products International, Inc. on October 15, 1985. It appears that Sterling Products International, Inc. is the manufacturer of WET ONES a first pop-up moist soft cloth towelettes for instant personal clean-ups when soap and water are out of reach, that its active ingredients are solution of skin emollients and softeners, detergents and other cleansing ingredients with 10% alcohol; that its general uses are to cleanse and refresh hands, face and neck at home, in the office, while travelling and at play or sports; and that among the raw materials used in making these WET ONES is the imported towelettes roll (un-woven fabric) In reply, please be informed that as manufacturer of WET ONES for the year 1985, Sterling Products International, Inc. is subject to the 10% sales tax on its manufactured WET ONES under the then Section 199(a) of the Tax Code, as amended. As such, any parts and accessories imported by Sterling Products International, Inc. during the year 1985 i.e., towelettes roll which are used in the manufacture of WET ONES shall be subject to the same rate of 10% advance sales tax prescribed by Section 199(a), in relation to Section 193(b), both of the Tax Code, as amended. Besides, the term "textiles" referred to in Section 185(p) [now Section 163(l)(1)] of the Tax Code, as amended, covers only woven fabrics. (BIR Ruling No. 015 dated February 24, 1959) Such being the case, the towelette rolls in question, being non-woven fabric, cannot be considered "textiles" to justify the imposition of a higher rate of advance sales tax. Very truly yours, (SGD.) BIENVENIDO A. TAN, JR. Commissioner