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 Vietnam
Dear Ms. Hodur:
In your letter dated July 8, 2025, you requested a tariff classification ruling. Your samples will be returned to
you, as requested.
Style 778736 is a women’s pajama top and bottom. Both garments are constructed from 50 percent rayon, 28
percent polyester and 22 percent nylon knit fabric. The blouse of style 778736 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 boat neck, hemmed, long sleeves with flared cuffs, and a hemmed bottom.
The lounge pants of style 778736 feature a self-fabric covered 3½ inch-wide elasticized waistband, and
flared, hemmed leg openings.
Style 782895 is a women’s pajama top and bottom. This style was previously addressed in New York Ruling
N349753, dated June 17, 2025, however you have provided an updated fiber content for this ruling. Both
garments are constructed from 48 percent rayon, 48 percent polyester and 4 percent spandex knit fabric. The
blouse of style 782895 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 with a front placket that is lined with five non-functional buttons, hemmed, long sleeves, and a
straight, hemmed bottom. The lounge pants of style 782895 feature a self-fabric covered 2-inch-wide
elasticized waistband, and hemmed leg openings.
In your 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. You 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 there is nothing about the styling, fabric, cut,
or construction of these garments which indicate that they were designed primarily for wear to bed. 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 applicable subheading for the blouses of styles 778736 and 782895 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 lounge pants of style 778736 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.
The applicable subheading for the lounge pants of style 782895 will be 6104.63.2011, 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 synthetic fibers: Other: Other: Trousers, breeches and shorts:
Women’s: Other. 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, 6104.69.2030, and 6104.63.2011, 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