CLA-2-61:OT:RR:NC:N1:361
Krisanne Stecklair
QVC, Inc.
1200 Wilson Drive
West Chester, PA 19380
RE: The tariff classification of a women’s knit garment from Vietnam
Dear Mr./Mrs./Ms. Stecklair:
In your letter dated June 2, 2025, you requested a tariff classification ruling. As requested, your sample is
being retained by this office.
Item number S99367/A702610 is a women’s top constructed from 90 percent rayon and 10 percent spandex
knit fabric. The sleeveless garment features a scooped front neckline, straps measuring approximately 2 and
½ inches, edging made of sewn-on contrasting fabric along the front and back necklines and at the armholes,
an upper back that is cut straight across from side seam to side seam, and a straight, hemmed bottom. The
garment extends from the shoulders to below the waist.
In your submission you suggest classification of item number S99367/A702610 as a tank top under heading
6109, Harmonized Tariff Schedule of the United States (HTSUS), however, this office finds that the garment
does not meet the requirements as a tank top and is specifically provided for as a top.
The applicable subheading for item number S99367/A702610 will be 6114.30.1020, HTSUS, which provides
for Other garments knitted or crocheted: Of man-made fibers: Tops, Women’s or girls’. The general rate of
duty will be 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. 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
6114.30.1020, HTSUS, listed above.
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 Antoinette Peek-Williams at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division