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

Elizabeth Hodur
KnitWell Group
7 Times Square
New York, NY 10036

RE: The tariff classification of women’s knit garments from Indonesia

Dear Ms. Hodur:

In your letter dated June 26, 2025, you requested a tariff classification ruling. Your samples will be returned to you, as requested.

Style 772167 is a women’s pajama top and bottom. Both garments are constructed from 92 percent modal, 8 percent spandex knit fabric. The blouse of style 772167 measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting blouse extends from the shoulders to below the waist and features a round front neckline with a partial opening secured by a six-button left over right closure, long sleeves and a hemmed bottom. The pull-on shorts of style 772167 feature a 1½ inch wide self- fabric covered tunnel elasticized waistband, side pockets and hemmed leg openings. The shorts extend from the waist to just above the knee.

Style 783082 is a women’s pullover sleepwear sleeveless dress constructed from 92 percent modal and 8 percent spandex knit fabric. The outer surface of the garment measures more than nine stitches per two centimeters in the direction the stitches were formed. The dress features a round neckline, finished armholes, and a finished hemline that extends to the ankle.

Style 783006 is a women’s pajama top and bottom. Both garments are constructed from 63 percent lyocell, 34 percent polyester and 3 percent spandex knit fabric. The blouse of style 783006 measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting blouse extends from the shoulders to below the waist and features a round neckline, hemmed, short sleeves, and a straight, hemmed bottom. The lounge pants of style 783006 feature a 1½ inch wide self-fabric covered elasticized waistband, and side slits at hemmed leg openings.

In your ruling request you indicate the garments will be sold together as a sleepwear pajama set with one price ticket and will feature the “LOFT SLEEP” label sewn onto each garment, and suggest the garments are classifiable under heading 6108, Harmonized Tariff Schedule of the United Sates (HTSUS), as pajamas sets. Although you refer to these garments as sleepwear, we find that garments of this style and construction are considered multi-use lounge wear garments that may be worn in a variety of informal situations in and around the home. The garments at issue may be worn to bed for sleeping, however, it is our opinion that their principal use is for “home comfort” and lounging. The garments can easily make the transition from inside the home (in a private setting) to outside the home (and a more social environment). As such, these garments are not classified as sleepwear, which is limited to garments that are designed for wear only to bed for sleeping.

The applicable subheading for the blouses of styles 772167 and 783006 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 will be 32 percent ad valorem.

The applicable subheading for the shorts of style 772167 will be 6104.69.2060, HTSUS, which provides for Women's shorts (other than swimwear), knitted or crocheted: Of other textile materials: Of artificial fiber: Shorts. The general rate of duty will be 28.2 percent ad valorem.

The applicable subheading for style 783082 will be 6104.44.2010, HTSUS, which provides for Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: Dresses: Of artificial fibers: Other: Women’s. The general duty rate will be 14.9 percent ad valorem.

The applicable subheading for the lounge pants of style 783006 will be 6104.69.2030, HTSUS, which provides for Women’s or girls’, suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: trousers, bib and brace overalls, breeches and shorts: Of other textile materials: Of artificial fibers: Trousers, breeches and shorts… Other: Trousers and breeches. 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 6106.20.2010, 6104.69.2060, 6104.44.2010, and 6104.69.2030, 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