CLA-2-39:OT:RR:NC:N3:348
Linda Diamant
Talbots Import LLC
840 E Beechwood Rd
Nixa MO 65714
RE: The tariff classification of a woman’s skirt from Vietnam
Dear Ms. Diamant:
In your letter dated October 20th, 2025, you requested a tariff classification ruling. Your sample will be
returned.
Style 254018451 is a women’s faux leather skirt. The garment is composed of cellular polyurethane plastic
with a rayon woven fabric backing present merely for reinforcing purposes. The fully lined garment features
a flat waistband, and a back zipper opening.
Although you requested classification under subheading 6210.50.3500, Harmonized Tariff Schedule of the
United States (HTSUS). Chapter 59 Note 2(a)(5) states that "Heading 5903 applies to: (a) Textile fabrics,
impregnated, coated, covered or laminated with plastics…other than: (5) Plates, sheets or strip of cellular
plastics, combined with textile fabric, where the textile fabric is present merely for reinforcing purposes
(chapter 39)." The textile fabric backing for the garment is used merely for reinforcing the cellular plastic.
Therefore, the skirt is considered made of plastic material of Chapter 39.
Consequently, the applicable subheading for style 254018451 will be 3926.20.9050, HTSUS, which provides
for Other articles of plastics and articles of other materials of heading 3901 to 3914: Articles of apparel and
clothing accessories (including gloves, mittens, and mitts): Other: Other, Other. The rate of duty will be 5
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 Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.69 or exclusion subheading, in addition to subheading 3926.20.9050, 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