CLA-2-48:OT:RR:NC:N1:130
Ms. Dana Posner
Hanes Brands, Inc.
1000 East Hanes Mill Road
Winston-Salem, NC 27105
RE: The tariff classification of a clothing tags from multiple countries
Dear Ms. Posner:
In your letter, dated November 12, 2018, you requested a tariff classification ruling. Samples, photos and product information were submitted for our review. The samples will be retained for reference.
The products under consideration are six printed paper tags that are designed for attachment to garments. Five items – AHJJVL, AHJKDN, AHJJWY, AHJJXH, and AHJML2 are paperboard tags of various shapes that are to be affixed to garments with plastic swift tack barbs, or to be folded and threaded over a hanger hook. Item ASJ072 is identified as a “merit” sticker. The country of origin of tag AHJJVL is Dominican Republic; of tag AHJML2, Thailand; of tag AHJKDN, El Salvador; and of tags AHJJWY, AHJJXH, and ASJ072, Honduras.
Item AHJJVL is a lithographically-printed, rectangular, paperboard tag that identifies the brand, “Champion”. It is also printed with features of the garment. The tag measures approximately 6.125” by 2.375”, is creased to fold over a garment edge, and is punched with two holes to accommodate a plastic swift tack barb. The barb attaches the tag to the garment.
Item AHJKDN is a lithographically-printed, rectangular, paperboard tag that identifies the brand, “Maidenform”, the style “Flexees”, and multiple features of the garment. The tag measures approximately 5.375” by 5.445”, is creased for folding, and is slotted to be threaded over a hanger hook.
Item AHJJWY is a lithographically-printed, paperboard tag that identifies the brand “Bali”, and includes catchphrases such as, “The Feel of Luxury”. The tag is generally in the shape of an “8”, and measures approximately 9.188” by 4.375”. It is creased for folding, and is slotted to be threaded over a hanger hook.
Item AHJJXH is a lithographically-printed, circular, paperboard tag that shows images of 8 bra configurations and the statement “8 Ways to Wear”. The tag is punched with a single hole to accommodate a plastic swift tack barb; the barb attaches the tag to the garment.
Item AHJML2 is a lithographically-printed, generally rectangular, paperboard tag that identifies the brand, “Maidenform”. It is also printed with images of bra configurations, and is printed with various features of the garment. The tag is punched with a single hole to accommodate a plastic swift tack barb; the barb attaches the tag to the garment.
Item ASJ072 is an adhesive sticker cut in the shape of a water drop. It is printed by flexographic process with the statement “Wicking Cool Comfort Fabric”. The sticker does not have any brand markings.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level (for the 4 digit headings and the 6 digit subheadings) and facilitate classification under the Harmonized Tariff Schedule of the United States (HTSUS) by offering guidance in understanding the scope of the headings and the General Rules of Interpretation (GRIs). While neither legally binding nor dispositive of classification issues, the ENs provide commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of the headings. See T.D. 89-80, 54 Fed. Reg. 35127-28 (Aug. 23, 1989). Heading 4821, HTSUS, provides for paper and paperboard labels. The ENs to heading 4821, HTSUS, state that:
This heading covers all varieties of paper and paperboard labels of a kind used for attachment to any type of article for the purpose of indicating its nature, identity, ownership, destination, price, etc. They may be of the stick-on type (gummed or self-adhesive) or designed to be affixed by other means, e.g., string.
These labels may be plain, printed to any extent with characters or pictures, gummed, fitted with ties, clasps, hooks or other fasteners or reinforced with metal or other materials. They may be perforated or put up in sheets or booklets.
Each of the instant tags are used for attachment to garments and indicate the brands and/or nature of the garments. As such, we find that each of the styles functions as a paper label of heading 4821, HTSUS.
The applicable subheading for the clothing tags numbered AHJJVL, AHJKDN, AHJJWY, AHJJXH, and AHJML2 will be 4821.10.2000, HTSUS, which provides for Paper and paperboard labels of all kinds, whether or not printed: Printed: Printed in whole or in part by a lithographic process. The rate of duty will be free.
The applicable subheading for the clothing tag numbered ASJ072 will be 4821.10.4000, HTSUS, which provides for Paper and paperboard labels of all kinds, whether or not printed: Printed:
Other. The rate of duty will be free.
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 https://hts.usitc.gov/current.
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 Laurel Duvall at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division