CLA-2-62:OT:RR:NC:N3:348
Paul Vroman
DHL Global Forwarding
2660 20th St.
Port Huron, MI 48060
RE: The tariff classification and eligibility under the United States-Mexico-Canada Agreement (USMCA) of
men’s outerwear from Mexico
Dear Mr. Vroman:
In your letter dated August 12, 2025, you requested a binding ruling on behalf of your client, Monty Limited,
on the tariff classification and eligibility of men’s jackets under the United States-Mexico-Canada Agreement
(USMCA).
The submitted sample, Style P4J0551A “Goodnight Grizzly,” is a men’s waist-length jacket. Part of the front
panels and the collar are constructed from 60% polyester and 40% acrylic knit fabric. The remainder of the
garment is constructed from 100% cotton woven fabric.
The lined garment has a full front opening with a five-button closure, a pointed collar, patch pockets at the
waist and buttoned cuffs. The jacket is an article of mixed components; the essential character is imparted by
the woven fabric.
Classification:
The applicable subheading for Style P4J0551A will be 6201.30.8051, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Men's or boys' overcoats, carcoats, capes, cloaks, anoraks
(including ski jackets), windbreakers and similar articles (including padded, sleeveless jackets), other than
those of heading 6203: Of cotton: Other: Other: Other: Other: Other: Men’s. The rate of duty will be 9.4
percent ad valorem.
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/current.
The manufacturing operations for this garment are as follows:
The cotton woven fabric originates in the United States.
The polyester/acrylic knit fabric, for the front panels and collar, is manufactured in China.
The fabric is cut, sewn and assembled into the finished garment in Mexico.
The sewing thread, used to assemble the components, is formed and finished in Mexico.
The garment is exported directly from Mexico to the U.S.
USMCA:
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN")
11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is
an originating good for purposes of the USMCA. GN 11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a "good originating in the territory of a USMCA country" only if-
(i) the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials; or
(iii) the good is a good produced entirely in the territory of one or more USMCA countries
using non-originating materials, if the good satisfies all applicable requirements set forth in
this note (including the provisions of subdivision (o)).
Since the jacket is constructed in part of non-originating materials, it is not considered a good wholly
obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is it produced exclusively from
originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN
11(b)(iii). As previously noted, the men’s jacket is classified under subheading 6201.30.8051, HTSUS.
The applicable rule of origin for goods classified under subheading 6201.30.8051, HTSUS, is found in GN
11(o)62.1, HTSUS, which provides:
A change to headings 6201 through 6204 from any other chapter, except from headings 5106 through
5113, 5204 through 5212, 5310 through 5311, chapter 54, headings 5508 through 5516, 5801 through
5802 or 6001 through 6006, provided that he good is both cut (or knit to shape) and sewn or otherwise
assembled in the territory of one or more of the USMCA countries
Chapter 62, Chapter rule 2 states: For the purposes of determining the origin of a good of this chapter, the
rule applicable to that good shall only apply to the component that determines the tariff classification of the
good and such component must satisfy the tariff change requirements set out in the rule for that good.
The component that determines the classification, the cotton woven fabric, originates in the United States.
Chapter 62, Chapter rule 4 states: Effective 12 months from the date of entry into force of the agreement, and
notwithstanding chapter rule 2 of this chapter, a good of this chapter containing sewing thread of headings
5204, 5401 or 5508, or yarn of heading 5402 used as sewing thread shall be considered originating only if
such sewing thread is both formed and finished in the territory of one or more of the USMCA countries
The sewing thread is formed and finished in Mexico.
Based on the facts provided, the goods described above qualify for USMCA preferential tariff treatment,
because they will meet the requirements of HTSUS General Note 11(b)(iii). The goods will therefore be
entitled to a Free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and
agreements.
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 Mexico are not
subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.01.27, in addition to subheading 6201.30.2050, HTSUS, listed above.
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 Rosemarie Hayward at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division