CLA-2 CO:R:C:G 082149 DSN

TARIFF No.: HTSUS 6116.93.2010

Mary E. Gill, Esquire
Sonnenberg, Anderson, O'Donnell & Rodriguez
200 West Adams Street
Suite 2625
Chicago, Illinois 60606

RE: Tariff classification of ladies' dress gloves

Dear Ms. Gill:

This is in reference to your letter of February 16, 1988, on behalf of Zwicker Knitting Mills, Inc., requesting the tariff classification of a ladies' dress glove under the Harmonized Tariff Schedule of the United States (HTSUSA). A sample produced in Haiti was submitted for examination.


The submitted sample, style number 5020-7, is a ladies' dress glove composed of acrylic knit fabric with a full overlaid leather back and a leather bow on the back. Overlaid leather strips also appear on the thumb, forefinger and part of the palm. According to your submissions, the leather weighs 14 ounces per dozen pairs. The textile portion weighs 16 ounces per dozen pairs. The value of the leather component is $26.11 per dozen and the value of the textile component is $6.28 per dozen.


Whether the gloves are classified under the HTSUSA according to the leather component or the textile component.


Classification of merchandise under the HTSUSA is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that the starting point is the terms of the headings and subheadings of the tariff and any


relevant section and chapter notes. There are no headings which refer to gloves composed of textile and leather. GRI 2(a), refers to articles which are incomplete or unfinished. GRI 2(a) is not applicable to the instant case because the merchandise is finished. GRI 2(b) provides than any reference in a heading to a material shall be taken to include combinations of that material with other materials, and that classification of goods consisting of more than one material shall be according to the principles of Rule 3 if they are prima facie classifiable under two or more headings. In the instant case, the glove is composed of textile fabric and leather, creating a situation where the article is classifiable under two headings.

GRI 3(a) provides that the heading with the most specific description of the merchandise is to be preferred. When two headings each refer to part only of the materials or substances contained in mixed or composite goods, those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete description of the goods. Heading 6116, HTSUSA, provides for gloves, mittens and mitts, knitted or crocheted. Heading 4203, HTSUSA, provides for articles of apparel and clothing accessories, of leather.

Since the merchandise at issue is a glove, heading 6116 is more specific than heading 4203. Therefore, pursuant to GRI 3(a), the gloves are classifiable in heading 6116. While the gloves may be "composite goods", the last portion of GRI 3(a), concerning such goods, is not applicable since heading 6116 does not refer to "materials or substances". See Headquarters Ruling Letter (HRL) 082185 of July 11, 1988, concerning classification of gloves which have an outer surface of rubber or plastics over a textile fabric.

The Explanatory Notes constitute the official interpretation of the tariff at the international level. The Explanatory Notes to Chapter 61 state that the classification of goods in this Chapter is not affected by the presence of parts or accessories of, for example, woven fabrics, furskin, feathers, leather, plastics or metal. Therefore, the presence of the leather on the gloves does not preclude classification in Chapter 61.


In view of the foregoing, the gloves are classified under subheading 6116.93.2010, HTSUSA, which provides for gloves,


mitten and mitts, knitted or crocheted, of synthetic fibers, other, without fourchettes, textile category 631, and dutiable at the rate of 19.8 percent ad valorem.

Due to the changeable nature of the statistical annotation and the restraint (quota/visa) categories, you should contact your local Customs office prior to importation of this merchandise to determine the current status of any import restraints or requirements.


John Durant, Director
Commercial Rulings Division