The tariff classification of a hat, a headband and a blanket from China

N352926 September 25, 2025 CLA-2-65:OT:RR:NC:N1:358 CATEGORY: Classification TARIFF NO.: 6505.00.6090, 6117.80.8500, 6301.40.0020, 9903.01.24, 9903.01.25, 9903.88.03, 9903.88.15 Nikolas Cromydas Oros Consumer LLC 140 Oxford Road Kenilworth, IL 60043 RE: The tariff classification of a hat, a headband and a blanket from China Dear Mr. Cromydas: In your letter dated August 26, 2025, you requested a tariff classification ruling. Three samples were submitted for our review and will be retained for reference. The first item, identified as the “Nova Beanie,” is a beanie-style hat constructed of an outer layer of 60 percent cotton and 40 percent acrylic rib knit fabric. The interior lining incorporates Solarcore® insulation which is constructed of 95 percent polyester and 5 percent Spandex. The beanie features a rounded crown and a close-fitting design that covers the head and ears, as well as a cuff that measures approximately 2.5 inches with a brand label “OROS” sewn in along the lower edge. The second item is a headband constructed of 80 percent polyester and 20 percent Spandex knit fabric. The circular headband measures approximately 3 inches in width and 20 inches in length. The third item, SKU #F25A200-100-OS, identified as “OROS SS24 Blanket,” is a quilted blanket comprised of six layers. The face side is composed of 92 percent polyester and 8 percent Spandex, dyed, woven fabric. The face fabric is a brushed pile fabric with the nonpile surface on the outer face. Below the face fabric are the following layers: 100 percent nitrile butadiene rubber (NBR) Solarcore® foam; 100 polyester nonwoven fabric; 100 percent polyester knit mesh fabric; a second layer of 100 percent nitrile butadiene rubber (NBR) Solarcore® foam; and a backing of 48 percent nylon, 45 percent rayon and 7 percent Spandex, dyed, knit fabric. The face layer, top layer of Solarcore® foam and layer of nonwoven polyester fabric are quilted together with the OROS logo pattern design. The layer of knit mesh, the bottom layer of Solarcore® foam and the knit backing are separately quilted together. All layers are assembled together by sewing around the edges. The blanket measures 50 x 60 inches, has rounded corners, and is finished with self-fabric binding. A 3 ½ x 2 inch woven label with the “OROS” logo is folded over the bottom edge and sewn to the face and back fabrics. You state that the item is designed to provide warmth in extreme cold to an individual. Classification under the Harmonized Tariff Schedule of the United States (HTSUS), is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. According to GRI 3(b), mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, shall be classified as if they consisted of the material or component which gives them their essential character. When goods cannot be classified by reference to GRI 3(a) or 3(b), they are classified under the heading which occurs last in numerical order among those which equally merit consideration. The beanie-style hat is constructed of different types of fabric in the outer and inner layer and therefore, considered a composite good. In this case, the essential character is imparted by the polyester interior lining, the Solacore® paneling, which delivers the thermal retention properties of the hat, as indicated in your request. In the case of the blanket, because it is composed of multiple different fabrics, we are of the opinion that no single component imparts the essential character, it cannot be classified under GRI 3(b). Therefore, applying GRI 3(c), the blanket will be classified in the provision which occurs last in numerical order. The applicable subheading for the beanie-style hat will be 6505.00.6090, HTSUS, which provides for “Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed; hair-nets of any material, whether or not lined or trimmed: Other: Other: Of man-made fibers: Knitted or crocheted or made up from knitted or crocheted fabric: Not in part of braid: Other: Other: Other.” The general rate of duty will be 20 cents per kilogram plus 7 percent ad valorem. The applicable subheading for the headband will be 6117.80.8500, HTSUS, which provides for “Other made up clothing accessories, knitted or crocheted; knitted or crocheted parts of garments or of clothing accessories: Other accessories: Other: Headbands, ponytail holders and similar articles.” The general rate of duty will be 14.6% ad valorem. The applicable subheading for SKU #F25A200-100-OS, identified as “OROS SS24 Blanket,” is classified under subheading 6301.40.0020, HTSUS, which provides for “Blankets and traveling rugs: Blankets (other than electric blankets) and traveling rugs, of synthetic fibers: Other.” The general rate of duty will be 8.5 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 6505.00.6090, 6117.80.8500 and 6301.40.0020, 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 6117.80.8500, 6505.00.6090, and 6301.40.0020, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6505.00.6090; HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 6505.00.6090, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6117.80.8500; 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 6117.80.8500, 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 Designated Official Performing the Duties of the Division Director National Commodity Specialist Division