CLA-2-65:OT:RR:NC:N1:358
Lesa Hubbard
JCPenney
6501 Legacy Drive, Suite B100
Plano, TX 75024
RE: The tariff classification of hats from China
Dear Ms. Hubbard:
In your letter dated April 28, 2025, you requested a tariff classification ruling.
Style #379908 is a cloche-style hat composed of 100 percent polyester knit fabric. The hat features a
downward-sloping brim that measures approximately 2 inches in width, a rounded crown with a ribbon band
around the base of the exterior and a sweatband on the inside.
Style #363771 is a fedora-style hat composed of 100 percent polyester knit fabric. The crown of the hat is
pinched in the front and has a center dent. The medium width brim measures approximately 2.5 inches and
has a slight downward curve. The hat has a sweatband on the inside and features a leather-like band adorned
with small metallic studs and a small buckle on the exterior.
Style # 379900 is a fedora-style hat composed of 100 percent polyester knit fabric. The crown of the hat is
pinched in the front and has a center dent. The medium width brim measures approximately 2 inches. The hat
has a sweatband on the inside and features a leather-like band adorned with small metallic studs and a small
buckle on the exterior.
The last item, identified as “Men’s Hat 4,” is a fedora-style hat composed of 100 percent polyester knit
fabric. The crown of the hat is pinched in the front and has a center dent. The medium width brim measures
approximately 2 inches. The hat has a sweatband on the inside and features a black fabric band with a bowtie
on the exterior.
In your letter, you stated that the hats are neither knit nor woven fabric and suggested classification under
subheading 6505.00.8090, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Further
analysis of the material used in the hats indicated that they are made of knit construction.
The applicable subheading for all four styles will be 6505.00.6090, HTSUS, which provides for “Hats and
other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in
strips), whether or not lined or trimmed; hair-nets of any material, whether or not lined or trimmed: Other:
Other: Of man-made fibers: Knitted or crocheted or made up from knitted or crocheted fabric: Not in part of
braid: Other: Other: Other.” The general rate of duty will be 20 cents per kilogram plus 7 percent ad valorem.
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 6505.00.6090, 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. At this time products from all 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
6505.00.6090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6505.00.6090, 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 6505.00.6090, 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