CLA-2-65:OT:RR:NC:N1:358
Jaime Sikes
Design Resources Inc.
7007 College Blvd, Suite 700
Overland Park, KS 66211
RE: The tariff classification of a baseball-style hat from Bangladesh
Dear Ms. Sikes:
In your letter dated September 2, 2025, you requested a tariff classification ruling. The submitted sample will
be retained for reference.
The submitted sample, identified as style C25-02422, is a men’s baseball-style cap. The cap is composed of
six panels. The front two panels are constructed of 75% nylon and 25% Spandex woven fabric. The back four
panels are constructed of 100% polyester knit mesh fabric. The cap features a fabric covered button at the
apex of the crown, two eyelets on the front panels, a silicone patch logo affixed to the front exterior and a
plastic adjustable strap at the rear.
Goods that are, prima facie, classifiable under two or more headings are classifiable in accordance with
General Rule of Interpretation (GRI) 3, Harmonized Tariff Schedule of the United States (HTSUS). GRI 3(b)
states in relevant part that “composite goods consisting of different materials or made up of different
components… which cannot be classified by reference to 3(a) shall be classified as if they consisted of the
material or component that gives them their essential character…” Here, there is no dispute that the cap is
classified in heading 6505, as the materials that make-up the cap are classified within this heading. Rather,
the issue is the proper classification at the subheading level. Style C25-02422 is prima facie, classifiable
under two subheadings. Neither the front two panels of woven fabric (6505.00.20, HTSUS) nor the polyester
knit mesh (6505.00.60, HTSUS) imparts the essential character of the cap. As a result, GRI 6, which governs
classification at the subheading level, applies as well.
The applicable subheading will be 6505.00.6090, HTSUS, which provides for “Hats and other headgear,
knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether
or not lined or trimmed; hair-nets of any material, whether or not lined or trimmed: Other: Other: Of
man-made fibers: Knitted or crocheted or made up from knitted or crocheted fabric: Not in part of braid:
Other: Other: Other.” The general rate of duty will be 20 cents per kilogram plus 7 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 of Bangladesh 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. 9903.02.05, in addition to subheading
6505.00.6090, 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 Katherine Souffront at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division