CLA-2-62:RR:NC:WA:361

Mr. Jerry Armani,
Director of Administration
Mamiye Brothers, Inc.
112 West 34th Street, Suite 1000
New York, NY 10120-0018

RE: The tariff classification of a skirt with a detachable bib from China.

Dear Mr. Armani:

In your letter dated November 6, 2006, you requested a classification ruling for a skirt with a detachable bib. The sample will be returned, as requested.

The submitted sample, marked as style number BJ001, is a junior size skirt with a detachable bib constructed from 100 percent cotton woven blue denim fabric. The pleated skirt has a flat waistband with belt loops, and an unfinished bottom. The bib is approximately 10 inches high and 9 inches wide and has a front patch pocket, and adjustable shoulder straps. The bib snaps onto the inner waistband of the skirt by means of two front snaps and a snap for each of the shoulder straps. The skirt can be worn without the bib.

The skirt and bib are sold together at retail as a unit. They are adapted to each other, are mutually complementary and together form a whole that would not normally be offered for sale in separate parts. As such, they meet the definition of a composite good found in the Explanatory Notes to the General Rules of Interpretation, 3(b). The essential character of style BJ001 is imparted by the skirt. The applicable subheading for style BJ001 will be 6204.52.2030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Women’s…skirts…: Of cotton: blue denim. The duty rate will be 8.2% ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

Style BJ001 falls within textile category 342. With the exception of certain products of China, quota/visa requirements are no longer applicable for merchandise which is the product of World Trade Organization (WTO) member countries. The textile category number above applies to merchandise produced in non-WTO member-countries. Quota and visa requirements are the result of international agreements that are subject to frequent renegotiations and changes. To obtain the most current information on quota and visa requirements applicable to this merchandise, we suggest you check, close to the time of shipment, the “Textile Status Report for Absolute Quotas” which is available on our web site at www.cbp.gov. For current information regarding possible textile safeguard actions on goods from China and related issues, we refer you to the web site of the Office of Textiles and Apparel of the Department of Commerce at otexa.ita.doc.gov.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Angela DeGaetano at 646-733-3052.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division