CLA-2-95:OT:RR:NC:N4:425
Mr. Frank Gomez
World Exchange, Inc.
7930 El Manor Ave
Los Angeles, CA 90045
RE: The tariff classification of a costume from China and Vietnam.
Dear Mr. Gomez:
In your letter dated August 12, 2025, you requested a tariff classification ruling on behalf of your client,
California Costume, Inc.
You submitted a sample of a child size costume identified as Posh Pirate, item number 00450, which consists
of a long-sleeved pullover top, pull-on pants, boot tops, belt and head tie. General Rule of Interpretation 3(b)
is applicable when goods are, prima facie, classifiable under two or more headings, and have been put up in
sets for retail sale. GRI 3(b) states that the goods “shall be classified as if they consisted of the material or
component which gives them their essential character.” The flimsy, man-made knitted textile top provides the
essential character of the set. The off-the-shoulder top features a raw, unfinished back neck. The front neck
has a raw, unfinished ruffle and a faux lace-up front with a non-functional, unfinished cord attached to the
neck. The tops and bottoms of the sleeves have narrow, exposed elastic, stitched on with a single row of long,
loose straight stitching. The tops and bottoms of the sleeves also have raw, jagged cut edges, giving a tattered
appearance. The hem bottom is raw and unfinished. Although the front of the top features faux vest panels,
the top is not well made. The top is stitched together with a single row of long, loose straight stitching.
The applicable subheading for the Posh Pirate costume, item number 00450, will be 9505.90.6000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Festive, carnival or other
entertainment articles, including magic tricks, and practical joke articles; parts and accessories thereof: Other:
Other. The rate of duty will be free.
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 subheading 9505.90.6000, 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. 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
9505.90.6000, 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. At this time, products of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
9505.90.6000, 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/.
Please note that separate Federal Trade Commission marking requirements exist regarding country of origin,
fiber content, and other information that must appear on many textile items. You should contact the Federal
Trade Commission, Division of Enforcement, 600 Pennsylvania Avenue, N.W., Washington, D.C., 20580,
for information on the applicability of these requirements to this item. Information can also be found at the
FTC website. www.ftc.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 Sandra Carlson at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division