CLA-2-61:N3:356
Taerim Kim
Hansoll Textile Ltd.
268, Songpa-Daero
Seoul 05719
South Korea
RE: The tariff classification of women’s upper body garments from Vietnam
Dear Taerim Kim:
In your letter dated March 9, 2026, you requested a tariff classification ruling.
Style 260309A is women’s upper body garment constructed from lightweight, 67 percent cotton and 33
percent polyester knit fabric that is lightly napped on its inner surface. The outer surface of the fabric
measures more than nine stitches per two centimeters in the direction the stitches were formed. Style
260309A extends from the shoulders to below the waist and features a full front opening with a zippered
closure, a band collar, long sleeves with rib knit cuffs, vertical welt pockets on the front panels below the
waist, mesh knit pockets on the inner front panels below the waist, and a rib knit bottom band. The upper
back of the garment features a 6-inch by 4½-inch heat transfer depicting a scene from the Disney movie
“Lady and the Tramp.” It is applied diagonally and partially obscures a trademark underneath; when the heat
transfer is peeled away from the garment, the trademark is revealed to be “Project Rock®”.
Style 260309B “Henley Hoodie” is a women’s shirt constructed from 60 percent cotton and 40 percent
polyester rib knit fabric that measures more than 10 stitches per linear centimeter in both the horizontal and
vertical directions. Style 260309B extends from the shoulders to below the waist and features a partial front
opening with seven button closures, a self-fabric hood, long sleeves with self-fabric cuffs, and a self-fabric
bottom band that does not provide tightening to the bottom of the garment.
Style 260309C “Raw Edge Henley Cami” is a women’s garment that is similar to a tank top. It is constructed
from 60 percent cotton and 40 percent polyester knit fabric. Style 260309C extends from the shoulders to
below the waist and features a henley-style partial front opening with two button closures, a button hole at
the top of the neckline without a corresponding button, a curved front neckline, a curved rear neckline that
reaches below the nape of the neck, ½-inch wide shoulder straps, and a straight, hemmed bottom.
Although you identify Style 260309A as a “bomber jacket,” the submitted sample lacks the character of an
outerwear jacket. Its styling, cut, and features do not support a finding that this item is an outerwear jacket
designed for wear over all other clothing for protection against the weather.
The applicable subheading for Style 260309A will be 6110.20.2079, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for: Sweaters, pullovers, sweatshirts; waistcoats (vests) and similar
articles, knitted or crocheted: Of cotton: Other: Other: Other: Women’s or girls’: Other. The general rate of
duty will be 16.5 percent ad valorem.
The applicable subheading for Style 260309B will be 6106.10.0010, HTSUS, which provides for: Women’s
or girls’ blouses and shirts, knitted or crocheted: Of cotton: Women’s. The general rate of duty will be 19.7
percent ad valorem.
The applicable subheading for Style 260309C will be 6109.10.0070, HTSUS, which provides for: T-shirts,
singlets, tank tops and similar garments, knitted or crocheted: Of Cotton: Women’s or Girls’: Other: Other.
The general rate of duty will be 16.5 percent ad valorem.
Style 260309A is not marked with its country of origin. Section 134.11 of the Customs Regulations (19
C.F.R. 134.11) provides, in part:
Unless excepted by law... every article of foreign origin (or its container) imported into the U.S. shall be
marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container)
will permit, in such a manner as to indicate to an ultimate purchaser in the U.S. the English name of the
country of origin of the article, at the time of importation into the Customs territory of the U.S. Further,
Treasury Decision (T.D.) 54640(6) (1958) provides, in pertinent part: Subject to the exceptions from
marking provided under Section 304(a), Tariff Act of 1930, as amended… wearing apparel, such as shirts,
blouses, coats and sweaters, etc., must be legibly and conspicuously marked with the name of the country of
origin by means of a fabric label or label made from natural or synthetic film sewn or otherwise permanently
affixed on the inside center of the neck midway between the shoulder seams or in that immediate area or
otherwise permanently marked in that area in some other manner.
Additionally, Style 260309A is not marked with its fiber content. Textile fiber products imported into the
United States must be labeled in accordance with the Textile Fiber Products Identification Act (15 U.S.C. 70
through 70k) and the rules promulgated thereunder by the Federal Trade Commission. We suggest you
contact the Federal Trade Commission, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580 for
information concerning the requirements of this Act. Information may also be obtained at the Federal Trade
Commission website, www.ftc.gov.
Finally, importations of Style 260309A may be subject to the provisions of Section 133 of the Customs
Regulations if the good features copies or simulations of registered trademarks, trade names, or copyrights
recorded with U.S. Customs and Border Protection (CBP). If you are an authorized importer of this good, we
recommend notifying your local Customs office prior to importation. At time of entry, CBP may choose to
verify your right to import goods featuring copies or simulations of such registered trademarks, trade names,
or copyrights.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Maryalice Nowak at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division