CLA-2-61:OT:RR:NC:N1:358
Dijana Milun
Terrible 2’s Solutions Inc.
113 Carla Lane
Buffalo, NY 14224
RE: The tariff classification of a boy’s garment from China
Dear Ms. Milun:
In your letter dated May 8, 2025, you requested a tariff classification ruling.
Style 02R23 is a boy’s romper constructed of 100% cotton knit fabric. The short-sleeve garment features a
crewneck, mid-thigh shorts and a full back zipper closure. In subsequent correspondence, you indicated that
the garment will be imported in sizes 2T, 3T, 4T and 5T.
The applicable subheading for style 02R23 will be 6114.20.0035, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for other garments, knitted or crocheted: of cotton, sunsuits, washsuits,
one-piece playsuits and similar apparel: boys’. The general rate of duty will be 10.8 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 6114.20.0035, 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 6114.20.0035, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 6114.20.0035, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, 9903.88.15, in
addition to subheading 6114.20.0035, 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.
The tariffs and additional duties cited above are current as of this ruling?s issuance. 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