CLA-2-61:OT:RR:NC:N1:361
Ms. Angie McDaniel
Johnny Was
712 S. Olive Street
Los Angeles, CA 90014
RE: The tariff classification of women’s knit blouses from China
Dear Ms. McDaniel:
In your letter dated June 25, 2025, you requested a tariff classification ruling. Your samples will be returned
as requested.
Style J28025-O is a women’s blouse constructed from 100 percent cotton terry 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 self-fabric lined hood with a drawstring, long sleeves
with rib knit cuffs, contrasting color embroidery at the outer hood, front panel and outer sleeves, a slightly
longer back panel, and a rib knit bottom with notched side seams.
Style J17925-O is a women’s blouse constructed from 100 percent cotton terry 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, long sleeves with rib knit cuffs,
contrasting color embroidery at the front panel, and a rib knit bottom with notched side seam.
In your ruling request you suggest classification of styles J28025-O and J17925-O under heading 6110,
Harmonized Tariff Schedule of the United States (HTSUS). However, by application of General Rules of
Interpretation 1 and 6, the appearance of the garments, and the definition in accordance with the reasoning set
forth in Headquarters Rulings H32560 and H324935, dated May 22, 2022, we find that styles J28025-O and
J17925-O are loose-fitting blouses of heading 6106, HTSUS. Styles J28025-O and J17925-O have
characteristics common to blouses, as enumerated in Note 4 to Chapter 61, HTSUS, therefore, precluding
them from heading 6110.
The applicable subheading for styles J28025-O and J17925-O 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 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 6106.10.0010, 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. 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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6106.10.0010, 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 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