The tariff classification of girls’ garments from China

N352861 September 15, 2025 CLA-2-61:OT:RR:NC:N1:358 CATEGORY: Classification TARIFF NO.: 6114.30.1020, 6104.63.2060, 9903.01.24, 9903.01.25, 9903.88.15 Stephanie Rodriguez BMI Target, LLC 1 Campus Rd Totowa, NJ 07512 RE: The tariff classification of girls’ garments from China Dear Ms. Rodriguez: In your letter dated August 25, 2025, you requested a tariff classification ruling. The submitted samples will be retained for training purposes. Style CB109C, identified as “Dance Tutu Shorts,” consists of two coordinated garments constructed of 28.5 percent cotton, 37.5 percent rayon, 28.5 percent acrylic and 5.5 percent Spandex knit fabric. The top is a sleeveless pullover that features a square neckline, shoulder straps measuring approximately 1.5 inches wide, an elasticized smocked bodice, and a flared lower portion. The pull-on shorts feature an encased elasticized waistband with a decorative satin bow, an attached mesh overskirt sewn to the waistband and hemmed leg openings. In subsequent correspondence you indicated that the garments will be imported in sizes Toddler (2-4), Small (4-5), and Intermediate (6-6x). Style CB110C, identified as “Lounge Set,” consists of two coordinated garments constructed of 87 percent polyester and 13 percent Spandex knit fabric. The top is a sleeveless pullover that features a square neckline, shoulder straps measuring approximately 1.5 inches wide, an elasticized smocked bodice, and a flared lower portion. The pull-on shorts have an encased elasticized waistband and hemmed leg openings. In subsequent correspondence you indicated that the garments will be imported in sizes: Toddler (2-4), Small (4-5), and Intermediate (6-6x). Note 14 to Section XI, Harmonized Tariff Schedule of the United States (HTSUS), requires that textile garments of different headings be separately classified. The girls’ garments are classified under two different headings thus preventing classification of style CB109C and CB110C as sets. The applicable subheading for the upper body garments in both styles will be 6114.30.1020, HTSUS, which provides for “Other garments, knitted or crocheted: Of man-made fibers: Tops: Women’s or girl’s”. The general rate of duty will be 28.2 percent ad valorem. The applicable subheading for the shorts in both styles will be 6104.63.2060, HTSUS, which provides for “Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: Trousers, bib and brace overalls, breeches and shorts: Of synthetic fibers: Other: Other: Shorts: Girls’: Other.” The general rate of duty will be 28.2 percent ad valorem. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 6114.30.1020 and 6104.63.2060, HTSUS, listed above. 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 China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 6114.30.1020 and 6104.63.2060, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6114.30.1020 and 6104.63.2060, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 6114.30.1020 and 6104.63.2060, 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 katherine.souffront@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division