The tariff classification of garments from China and Vietnam

N265348 June 26, 2015 CLA-2-61:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 6110.30.3035; 6113.00.1012 Ms. Vicky Lee J. Crew Group, Inc. 770 Broadway, 14th Floor New York, NY 10003 RE: The tariff classification of garments from China and Vietnam Dear Ms. Lee: In your letter dated May 21, 2015, you requested a tariff classification ruling. The samples submitted will be returned as requested, except for style E2717, which will be retained by this office. Style D315051, imported from Vietnam, is a pair of women’s pants. The pants are constructed from 100% viscose rayon knit fabric coated with a cellular plastic that completely obscures the underlying fabric. The garment features an approximately 1 ½ inch exposed elastic waistband, hemmed leg openings, and an approximately seven inch rear center zipper. The unlined pants are of cellular plastic construction; however, the fabric is used in lieu of a lining for comfort and therefore, used for more than mere reinforcement. Style E2717, imported from China, is a girl’s size 6/7, sleeveless vest constructed from two fabrics. The two front panels are constructed from a 49% modacrylic, 26% acrylic, and 25% polyester finely knit faux fur long pile fabric. The back panel, stand up collar, placket and front banded bottom are constructed from 40% wool, 35% nylon and 25% viscose rib-knit fabric. The inner surface of the pile fabric measures more than nine stitches per two centimeters in the horizontal direction and is lined with a 100% polyester woven fabric. The garment features sleeveless armholes and a full front opening with a zippered closure. The essential character, for Style E2717, is imparted by the long knit pile fabric of the front panels, Harmonized Tariff Schedule of the United States (HTSUS), General Rules of Interpretation (GRI), Rule 3(b), noted. The applicable subheading for style D315051 will be 6113.00.1012, HTSUS, which provides for Garments, made up of knitted or crocheted fabrics of heading 5903, 5906, or 5907: having an outer surface impregnated, coated, covered or laminated with rubber or plastics material which completely obscures the underlying fabric, other. The rate of duty will be 3.8% ad valorem. The applicable subheading for Style E2717 will be 6110.30.3035, HTSUS, which provides for “Sweaters, pullovers, sweatshirts, waistcoats (vests) and similar articles, knitted or crocheted: Other: Other: Other: Other: Vests, other than sweater vests: Women’s or girls.” The rate of duty will be 32 percent ad valorem. Regarding Style E2916, we are returning your request and any related samples, exhibits, etc. We need additional information in order to issue a ruling. Please submit the information described below: Please provide a sample of the merchandise. Please provide the cost breakdown for the leather, fabric and fob of the garment. Please provide a detailed manufacturing sequence for Style E2916. 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 on World Wide Web at http://www.usitc.gov/tata/hts/. This ruling is being issued under the provisions of Part 177 of the Customs 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 style D315051, contact National Import Specialist Rosemarie Hayward via e-mail at rosemariecasey.hayward@cbp.dhs.gov. If you have any questions regarding style E2717, contact National Import Specialist Kim Wachtel via e-mail at kimberly.a.wachtel@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division