CLA-2-61:OT:RR:NC:N1:361
Min Xie
PVH Corp
285 Madison Ave
New York, NY 10017
RE: The tariff classification of women’s knit blouses from Vietnam and the Dominican Republic
Dear Ms. Xie:
In your letter dated June 17, 2025, you requested a tariff classification ruling. Your samples will be returned
to you as requested.
Style A is a women’s blouse constructed from 100 percent cotton jersey knit fabric that measures at least 10
or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from
the shoulders to below the waist and features a rib-knit crew neckline, contrasting color letters located on the
upper front panel, short, hemmed sleeves, and a hemmed bottom.
Style B is a women’s blouse constructed from 100 percent cotton jersey knit fabric that measures at least 10
or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from
the shoulders to below the waist and features a rib-knit crew neckline, a contrasting color logo on the upper
portion of the front panel, short, hemmed sleeves, and a hemmed bottom.
In your ruling request you suggest classification of style A under heading 6109, Harmonized Tariff Schedule
of the United States (HTSUS), and style B under heading 6110, HTSUS. However, by application of GRI 1
and 6, the appearance of the garments, and the definition in accordance with the reasoning set forth in
Headquarters Rulings H325360 and H324935, dated May 22, 2022, we find that style A and B are
loose-fitting blouses of heading 6106, HTSUS. Styles A and B have characteristics common to blouses, as
enumerated in Note 4 to Chapter 61, HTSUS, therefore, precluding them from headings 6109 and 6110.
The applicable subheading for style A and B will be 6106.10.0010, HTSUS, which provides for: Women’s or
girls’ blouses and shirts, knitted or crocheted: Of cotton: Women’s. The general rate of duty will be 19.7
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
6106.10.0010, 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)
James Forkan
Acting Director
National Commodity Specialist Division