CLA-2-61:OT: RR:NC:N1:361

Maurine Cecil
Western Overseas Corporation
10731 Walker St
Cypress, CA 90630

RE: The tariff classification of women’s wearing apparel from Vietnam

Dear Ms. Cecil:

In your letter dated June 25, 2025, you requested a tariff classification ruling on behalf of Careismatic Brands LLC. Your samples will be returned to you, as requested.

Style CK00011 is a women’s cardigan constructed from 80 percent polyester and 20 percent spandex knit fabric. The garment features a self-fabric two-ply constructed V-styled front and collar, a full front opening with a zippered closure, long sleeves with self-fabric cuffs, side entry pockets below the waist, a woven fabric label with the CHEROKEE ® trademark on the lower left-front panel, a back yoke, and a loose-fitting, self-fabric bottom band.

Style MC00017 is a women’s bodysuit constructed from knit and woven components. The upper portion is constructed from 95 percent polyester and 5 percent spandex woven fabric; the lower portion is constructed from 92 percent polyester and 8 percent spandex knit fabric. The one-piece garment features short, hemmed sleeves, a V-neckline, a single pocket at the left chest, and a two-snap crotch opening.

Style IN00026 is a women’s top constructed from 82 percent polyester and 18 percent spandex knit fabric. The garment features a built-in shelf bra that is securely sewn onto the neckline and armholes, a U-shaped front neckline, capping at the front neckline, elasticized edging at the rear neckline, flatlock stitching at the seams, forward shoulder seams, hemmed, long sleeves, a contrasting color logo at the center rear neckline, and a slightly curved, hemmed bottom. The garment extends from the shoulders to below the waist.

Style IN00027 is a women’s blouse constructed from 82 percent polyester and 18 percent spandex knit fabric. The blouse 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 crew neckline with a contrasting color rib knit front, a logo at the left side chest, hemmed, short sleeves, and a hemmed bottom with side seam slits. Style IN00028 is a women’s top constructed from 79 percent nylon and 21 percent spandex knit fabric. The sleeveless garment features a built-in shelf bra that is securely sewn onto the neckline and shoulders, a U-shaped front neckline, a logo at the left side chest, pleated fabric at the front panel, an inner pocket with a zippered opening at the lower left side and a hemmed bottom with a slightly curved and longer vented front panel.

In your ruling request, you suggest classification of style MC00017 under subheading 6211.43.1088, Harmonized Tariff Schedule of the United States (HTSUS). The features and the cut of the garment are of those of 6211 upper body garments excluded from heading 6206.

You also suggest classification of styles IN00026 and IN00027 under subheading 6109.90.1090, HTSUS and style IN00028 under subheading 6110.30.3059, HTSUS. We find the features and styling of styles IN00026 and IN00028 are those of a top under heading 6114, and the features and styling of style IN00027 are those of a blouse under heading 6106.

The applicable subheading for style CK00011 will be 6110.30.3059, HTSUS, which provides for Sweaters, pullovers, sweatshirts, waistcoats (vests) and similar articles, knitted or crocheted (con.): Of man-made fibers: Other: Other: Other: Other: Women’s or girls’: Other. The general rate of duty will be 32 percent ad valorem.

The applicable subheading for style MC00017 will be 6211.43.1059, HTSUS, which provides for Track suits, ski-suits and swimwear; other garments: Other garments, women’s or girls’: Of man-made fibers: Other: Blouses, shirts and shirt-blouses, sleeveless tank styles and similar upper body garments excluded from heading 6206: Designed for use in hospitals, clinics, laboratories or contaminated areas. The general duty rate will be 16 percent ad valorem.

The applicable subheading for style IN00026 and style IN00028 will be 6114.30.1020, HTSUS, which provides for Other garments, knitted or crocheted: Of man-made fibers: Tops: Women’s. The general rate of duty will be 28.2 percent ad valorem.

The applicable subheading for style IN00027 will be 6106.20.2010, HTSUS, which provides for Women’s or girls’ blouses and shirts, knitted, or crocheted: Of man-made fibers: Other: Women’s. The general rate of duty rate will be 32 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 6110.30.3059, 6211.43.1088, 6114.30.1020 and 6106.20.2010 HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance.

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