CLA-2-65:OT:RR:NC:N358

Igor Deynega
The Hatroom, Inc.
1200 W 35TH Street
Chicago, IL 60609

RE: The tariff classification of hat bodies from China

Dear Mr. Deynega:

In your letter dated April 15, 2025, you requested a tariff classification ruling.

You have submitted photographs and descriptive literature concerning three items. The first two items are addressed in this letter; the third item will be addressed in a separate letter.

The first item is a wool felt hat body. The hat body is unblocked and is designed in the shape of a crown and brim. It does not incorporate any linings, sweatbands, or additional decorative elements.

The second item is a straw hat body. The hat body is made of natural straw material, not blocked to shape, lined nor trimmed, and is designed in the shape of a crown and brim. It does not incorporate any linings, sweatbands, or additional decorative elements.

The applicable subheading for the felt hat body will be 6501.00.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Hat forms, hat bodies and hoods of felt, neither blocked to shape nor with made brims; plateaux and manchons (including slit manchons), of felt: Other.” The general rate of duty will be 10.3¢/kg + 10.3% ad valorem.

The applicable subheading for the straw hat body will be 6502.00.6030, HTSUS, which provides for “ Hat shapes, plaited or made by assembling strips of any material, neither blocked to shape, nor with made brims, not lined, nor trimmed: Of vegetable fibers, of unspun fibrous vegetable materials, of paper yarn or of any combination thereof: Not sewed: Bleached or colored: Of paper.” The general rate of duty will be free.

Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 6501.00.9000 or 6502.00.6030 HTSUS, listed above.

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. 9903.01.63, in addition to subheading 6501.00.9000 or 6502.00.6030, HTSUS, listed above.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6501.00.9000 and 6502.00.6030, 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 6501.00.9000 or 6502.00.6030, 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 at https://hts.usitc.gov/.

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 Katherine Souffront at [email protected].
Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division