CLA-2-62:OT:RR:NC:N3:360
Mr. Seunghyun Jung
Uniqlo USA LLC
165 Polito Avenue
Lyndhurst, NJ 07071
RE: The tariff classification of women’s trousers from China
Dear Mr. Jung:
In your letter dated May 27, 2025, you requested a tariff classification ruling. Your samples will be returned
as requested.
Item 469858 (04224F016A) is a pair of women’s trousers constructed from 66% polyester, 29% rayon, and
5% spandex woven fabric. The trousers feature a front fly opening with a zipper and metal button closure on
a flat waistband, five belt loops, two rear pockets, two front pockets, and hemmed leg openings.
Item 468583 (04224N126A) is a pair of women’s trousers constructed from 75% cotton and 25% nylon
woven fabric. The trousers feature a front fly opening with a zipper and snap button closure, a self-fabric
drawstring, a partially elasticized waistband, a single rear pocket, two front pockets, two cargo patch pockets,
and elasticized leg openings.
The applicable subheading for item 469858 (04224F016A) will be 6204.63.9011, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Women’s or girls’ suits, ensembles, suit-type
jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other
than swimwear): Trousers, bib and brace overalls, breeches and shorts: Of synthetic fibers: Other: Other:
Other: Other: Other: Trousers and breeches: Women’s: Other. The rate of duty will be 28.6 percent ad
valorem.
The applicable subheading for item 468583 (04224N126A) will be 6204.62.8018, HTSUS, which provides
for Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib
and brace overalls, breeches and shorts (other than swimwear): Trousers, bib and brace overalls, breeches and
shorts: Of cotton: Other: Other: Other: Other: Other: Women’s trousers and breeches: Other. The rate of duty
will be 16.6 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 subheadings 6204.63.9011, and 6204.62.8018, 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 subheadings
6204.63.9011, and 6204.62.8018, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 6204.63.9011, and 6204.62.8018, 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, i.e., 9903.88.15, in addition to subheading 6204.63.9011, and 6204.62.8018, 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, including
information on exclusions and their effective dates, 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.
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/.
At the time of Entry/Entry Summary, you may be requested to verify the information for any specific
shipment or product.
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 Kimberly Rackett at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division