The samples, packaged as “Venture Wipes,” are square 12 inch by 12 inch cleaning wipes. The wipe has a raised textured dot pattern. According to your submission the wipes are composed primarily of staple fibers and are impregnated with a solution which consists primarily of water in addition to aloe, calcium gluconate, tea tree oil and vitamin E. You state the purpose of the product is to cleanse the body in the manner of a cloth. Your letter also indicates the natural ingredients contained in the wipe assist in cleaning and freshening, but the purpose of the fabric is to remove dirt and perspiration. According to The U.S. Customs and Border Protection Laboratory, the wipes do not contain soap or surfactants. The sample tested was determined to be of nonwoven construction, composed of man-made fibers, with evidence of mechanical bonding. The tested sample weighs 75.4 grams per square meter when dry and 297.3 grams per square meter when wet. It is the opinion of this office that the nonwoven textile functions as more than merely a carrier for the water and other ingredients. The textured nonwoven surface directly facilitates the removal of dirt.
[1] Please importantly note that only the relevant portion of the related is displayed above. You may refer to the said customs ruling for the entire ruling explanation.
[1]. https://rulings.cbp.gov/ruling/N303545