OT:RR:NC:N1:361
May Lai
Cobalt Knitwear Limited
3/F 888 Cheung Sha Wan Road
Kowloon
Hong Kong
RE: Classification and country of origin determination for a women’s cardigan
Dear Ms. Lai:
This is in reply to your letter dated April 2, 2025, requesting a classification and country of origin
determination for women’s a knit cardigan, which will be imported into the United States.
Style 015-25C125593 is a women’s cardigan constructed of 60 percent cotton and 40 percent rayon. The
outer surface of the garment’s fabric measures more than nine stitches per two centimeters, but less than or
equal to eighteen stitches per two centimeters in the direction the stitches were formed. The garment features
a full front opening without closure, three-quarter length sleeves with rib knit cuffs, and a rib knit hem. The
garment reaches below the waist. All panels of the garment are considered knit to shape.
The applicable subheading for style 015-25C125593 will be 6110.20.2077, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for Sweaters, pullovers, sweatshirts, waistcoats (vests) and
similar articles, knitted or crocheted (con.): Of cotton: (con.): Other: Other: Women’s or girls: Knit to shape
articles described in statistical note 6 to this chapter. The general rate of duty will be 16.5 percent ad valorem.
COUNTRY OF ORIGIN:
The manufacturing operations for the style 015-25C125593 are as follows:
The panels for style 015-25C125593 are knitted to shape by a flatbed knitting machine in Cambodia. These
knitted panels will then be shipped to China. In China, the panels will be linked, looped, and assembled into
complete products, followed by printing, washing, pressing and packing.
Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 U.S.C. 3592), enacted on
December 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customs
laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or
withdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described as
Congress’s expression of substantial transformation as it relates to textile and apparel products. Section
102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of origin of
a textile or apparel product shall be determined by the sequential application of the general rules set forth in
paragraphs (c)(1) through (5) of section 102.21. See 19 CFR 102.21(c).
Paragraph (c)(1) states, “The country of origin of a textile or apparel product is the single country, territory,
or insular possession in which the good was wholly obtained or produced.” As the subject merchandise is not
wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section
102.21 is inapplicable.
Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or
insular possession in which each of the foreign materials incorporated in that good underwent an applicable
change in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) of
this section:”
Paragraph (e) in pertinent part states, “The following rules shall apply for purposes of determining the
country of origin of a textile or apparel product under paragraph (c)(2) of this section:”
HTSUS Tariff Shift and/or Other Requirement:
6101 - 6117 (1). If the good is not knit to shape and consists of two or more component parts, except for
goods of subheading 6117.10, provided for in paragraph (e)(2) of this section, a change to an assembled good
of heading 6101 through 6117 from unassembled components, provided that the change is the result of the
good being wholly assembled in a single country, territory or insular possession. Style 015-25C125593
qualifies as a knit to shape garment, therefore; Section 102.21(c)(2) is inapplicable
Paragraph (c)(3) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c) (1) or (2) of this section: if the good was knit to shape, the country of origin of the good
is the single country, territory, or insular possession in which the good was knit; or except for fabrics of
chapter 59 and goods of headings 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and
subheadings 6307.10, 6307.90, 9404.90, and 9619.00.31-33 if the good was not knit to shape and the good
was wholly assembled in a single country, territory, or insular possession, the country of origin of the good is
the country, territory, or insular possession in which the good was wholly assembled.”
As the subject merchandise is knit to shape, Section 102.21(c)(3) applies.
The country of origin for style 015-25C125593 is Cambodia.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 6110.20.2077, HTSUS, listed above.
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.
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 Antoinette Peek-Williams at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division