CLA-2-60:OT:RR:NC:N2:352
Maribeth Dedmon
Dollar General
100 Mission Ridge Goodlettsville, TN 37072
RE: The tariff classification of polyester knit imitation furskins from China
Dear Ms. Dedmon:
In your letter dated December 20, 2023, you requested a tariff classification ruling. Along with your request, you have submitted samples of an artificial brown fur fabric and an artificial white fur fabric.
Visual review shows that the products are each being marketed as “craft fur” with a designated SKU 36533401 for the brown colored fabric and SKU 36533501 for the white colored fabric. Your original submission indicates that the fiber content of each fabric is wholly of polyester, weighs 360 g/m2, and is manufactured on a circular knitting machine. Further research shows that the imitation fur fabrics will be utilized for a variety of craft uses such as “for wigs, doll hair, fur trim, and comfy throw pillows or blankets.” Physical review of the fabrics along with additional correspondence show that they are of knit pile construction made by inserting fibers from combed slivers into the loops of the ground fabric during knitting.
Statistical Note 1 to Chapter 60, Harmonized Tariff Schedule of the United States (HTSUS), states that “For purposes of statistical reporting numbers 6001.92.0010 and 6001.92.0030, the term ‘velour’ refers to fabrics containing 12 or more stitches per centimeter in the vertical direction.” This fabric contains 8 stitches per cm in the vertical direction, therefore, this fabric would not be considered velour.
The applicable subheading for the brown colored fur fabric, SKU 36533401, and the white colored fur fabric, SKU 36533501, will be 6001.92.0020, HTSUS, which provides for pile fabrics, including “long pile” fabrics and terry fabrics, knitted or crocheted: other: of man-made fibers, other: other. The rate of duty will be 17.2% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6001.92.0020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 6001.92.0020, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Nicole Rosso at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division