CLA-2-61:OT:RR:NC:N3:357
Maggie Iken
Kohl’s Corporation
N56 W17000 Ridgewood Drive
Menomonee Falls, WI 53051
RE: The tariff classification of a boys’ knitted jacket from Cambodia
Dear Ms. Iken:
In your letter dated April 14, 2025, you requested a tariff classification ruling. The sample will be returned.
Style EX5FA200RD is a boys’ jacket constructed from knit and woven components. The hood, the sleeves,
and the back panel are constructed from 50% rayon, 43% polyester, 7% spandex knitted fabric. The front
panels are constructed from a 93% nylon, 7% spandex woven fabric quilted in horizontal rows to a polyester
polyfill nonwoven batting.
The partially lined garment features a full front opening with a zipper closure that extends to the base of a
scuba-type hood, an inner storm flap, long sleeves with ribbed knit cuffs, zippered pockets below the waist,
and a ribbed knit bottom.
In your letter, you suggest the essential character of the garment is the woven fabric; however, the knit fabric
covers over 60% of the surface area of the garment and weighs and costs more than the woven fabric.
Applying the guidance specified in HQ memo 084118, the knit fabric provides the essential character of the
garment. Please note the woven fabric covers most but not all of the front of the garment, and the quilt
stitches are functional, serving to bind the woven fabric and batting layers together rather than producing a
decorative effect.
The applicable subheading for style EX5FA200RD is 6101.30.2020, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for: Men and boys’ overcoats, carcoats, capes, cloaks, anoraks
(including ski-jackets), windbreakers, and similar articles, knitted or crocheted, other than those of heading
6103: Of man-made fibers: Other: Other: Boys’. The rate of duty is 28.2 percent ad valorem.
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 6101.30.2020, 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 the 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 the 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 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 Deanna Boldt via email at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division