CLA-2-62:OT:RR:NC:N3:357
Ernesto Alacio
MWCPA LLC
8051 Central Park Ave
Skokie, IL 60076
RE: The tariff classification of men’s coveralls from Mexico
Dear Mr. Alacio:
In your letter dated November 11, 2025, you requested a tariff classification ruling. Your samples will be
returned.
Item SW-605-12-L is a men’s one-piece step-in-garment constructed from 88% cotton, and 12% nylon
woven fabric. The garment extends from the neck to the ankles and features a stand-up collar with hook and
loop closures, a left-over-right front with hook and loop closures, long sleeves with ribbed knit cuffs, and
hemmed leg openings with hook and loop closures at the ankles.
Item ACCA12RG-M is a men’s one-piece step-in-garment constructed from 88% cotton, and 12% nylon
woven fabric. The garment extends from the neck to the ankles and features a stand-up collar, a
left-over-right front with hook and loop closures, long sleeves with ribbed knit cuffs, a partially elasticized
waist, hemmed leg openings with hook and loop closures at the ankles.
Item 605-IND-N-44R is a men’s one-piece step-in-garment constructed from 100% cotton woven fabric. The
garment extends from the neck to the ankles and features a pointed collar, a left-over-right front opening
secured by two snap closures and partial zipper closures, long sleeves with snap closures, a partially
elasticized waist, pockets at the chest area, pockets below the waist, and hemmed leg openings.
Item 605-USN-L is a men’s one-piece step-in-garment constructed from 88% cotton, and 12% nylon woven
fabric. The garment extends from the neck to the ankles and features a pointed collar, a left-over-right front
opening secured by two snap closures and partial zipper closures, long hemmed sleeves, pockets at the chest
area, pockets below the waist, and hemmed leg openings.
Item AF-CV-A1-L is a men’s one-piece step-in-garment constructed from 88% cotton, and 12% nylon woven
fabric. The garment extends from the neck to the ankles and features a pointed collar, a left-over-right front
opening secured by two snap closures and partial zipper closures, long hemmed sleeves, pockets at the chest
area, pockets below the waist, and hemmed leg openings.
Item 605-INDN-MGCED-L is a men’s one-piece step-in-garment constructed from 100% cotton woven
fabric. The garment extends from the neck to the ankles and features a stand-up collar secured with a hook
and loop closure, a left-over-right front opening secured by two snap closures and partial zipper closures,
long sleeves with snap closures, pockets at the chest area, back pockets below the waist, and hemmed leg
openings.
The garments provide protection from electric arc flash, flash fire, molten ferrous metal and welding
exposures. Although not specifically provided for under a tariff heading, guidance as to their classification is
set out in the Explanatory Notes (EN). Heading 6211, Harmonized Tariff Schedule of the United States
(HTSUS), covers other woven garments. EN to heading 6211 states that the EN to heading 6114, HTSUS,
which concerns other knitted or crocheted garments, apply mutatis mutandis, to the articles of heading 6211,
HTSUS. The applicable EN to heading 6114, HTSUS, states, in pertinent part, as follows:
The heading includes, inter alia:
Aprons, boiler suits (coveralls), smocks and other protective clothing of a kind worn by mechanics, factory
workers, surgeons, etc. (Emphasis added).
In accordance with the EN to heading 6114, HTSUS, garments worn for protective purposes are classified as
wearing apparel under heading 6211, HTSUS.
The applicable subheading for items SW-605-12-L, ACCA12RG-M, 605-IND-N-44R, 605-USN-L,
AF-CV-A1-L, and 605-INDN-MGCED-L will be 6211.32.9010, HTSUS, which provides for Track suits,
ski-suits and swimwear; other garments: Other garments, men’s or boys’: Of cotton: Other: Other: Men’s.
The duty rate will be 8.1 percent ad valorem.
In your submission you requested consideration for classification under subheading 9802.00.9100, HTSUS.
Subheading 9082.00.9100, HTSUS covers, “Textile and apparel goods, assembled in Mexico in which all
fabric components, excluding visible lining fabrics, were wholly formed and cut in the United States,
provided that such fabric components, in whole or in part, (a) were exported in condition ready for assembly
without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape,
or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being
assembled and except by operations incidental to the assembly process; provided that the goods classifiable
in chapters 61, 62, or 63 may have been subject to bleaching, garment dyeing, stone-washing, acid-washing,
or perma-pressing after assembly.”
The manufacturing processes are as follows:
The cotton woven fabric rolls, originating from the United States, are shipped to Mexico.
In Mexico, the fabric is cut into components, sewn and assembled into the finished garments.
The garments are inspected, packaged and shipped to the United States.
Since the fabric components were cut in Mexico, 9802.00.9100, HTSUS, does not apply.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 6211.32.9010,
HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.01. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading 6211.32.9010, HTSUS.
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 6211.32.9010, 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 Rosemarie Hayward at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division