CLA-2-95:OT:RR:NC:N4:425
Mr. Frank Gomez
World Exchange, Inc.
7930 El Manor Ave
Los Angeles, CA 90045
RE: The tariff classification of a costume from China and Vietnam.
Dear Mr. Gomez:
In your letter dated June 8, 2025, you requested a tariff classification ruling on behalf of your client,
California Costume, Inc.
You submitted a sample of a toddler size costume identified as Little Pilgrim Boy, item number 2125-106,
which consists of a long-sleeved pullover top, pull-on pants, hat, belt and shoe buckles. General Rule of
Interpretation 3(b) is applicable when goods are, prima facie, classifiable under two or more headings, and
have been put up in sets for retail sale. GRI 3(b) states that the goods “shall be classified as if they consisted
of the material or component which gives them their essential character.” The flimsy man-made knitted
textile top provides the essential character of the set and features a single ply collar with raw unfinished
edges, the neck also has a deep back opening with raw, unfinished edges, closed by a single tab of hook and
loop fastener. The long sleeves end in a folded band. The hem bottom is raw and unfinished. Although there
is some capping on top of the flimsy collar, the top is not well-made. The top is stitched together with long,
loose, straight stitching.
The applicable subheading for the Little Pilgrim Boy costume, item number 2125-106, will be 9505.90.6000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Festive, carnival or other
entertainment articles, including magic tricks, and practical joke articles; parts and accessories thereof: Other:
Other. The 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 9505.90.6000, 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
9505.90.6000, 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/.
Please note that separate Federal Trade Commission marking requirements exist regarding country of origin,
fiber content, and other information that must appear on many textile items. You should contact the Federal
Trade Commission, Division of Enforcement, 600 Pennsylvania Avenue, N.W., Washington, D.C., 20580,
for information on the applicability of these requirements to this item. Information can also be found at the
FTC website www.ftc.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 Sandra Carlson at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division