The tariff classification of girls’ costumes from China

N353021 September 22, 2025 CLA-2-62:OT:RR:NC:N1:358 CATEGORY: Classification TARIFF NO.: 6211.43.1092, 6204.53.302, 6217.10.9530, 9903.01.24, 9903.01.25, 9903.88.15 Cathy Yu JAKKS Pacific 21749 Baker Pkwy Walnut, CA 91789 RE: The tariff classification of girls’ costumes from China Dear Ms. Yu: In your letter dated August 28, 2025, you requested a tariff classification ruling. Three samples were submitted for our review. Styles 251241, 251251 and 251271, identified as “Moana Classic Dress,” are composed of three pieces, an upper body garment, a skirt, and a sash. The upper body garment is constructed of 100 percent polyester woven fabric on the front and 100 percent polyester knit fabric on the back. The skirt has a sash and an inner layer constructed of 100 percent polyester woven fabric. All components are well-made with sturdy seams and styling details. The upper body garment features well-made spaghetti straps and a self-fabric overlay positioned above the main body panel that extends across the neckline diagonally with a tight merrow stitch at the hem. The garment does not reach the waist. The sash measures approximately 18" by 6" and has clean finished turned and stitched edges. The multi-layer skirt features a tunnel elastic waistband with a tight merrow stitch on a scalloped edge hem. The inner layer features narrow, loose-hanging strips. The articles will be imported in the following sizes with their respective style numbers: Size 3 under style 251241, size 4 under style 251251, and size 7-8 under style 251271. In your letter, you state you believe these costumes are properly classified under heading 9505 as “festive articles.” Costumes are considered “fancy dress.” The Court of Appeals ruled on the classification of costumes in its decision in Rubie’s Costume Co. v. United States, Slip Op 02-1373 (Fed. Cir. Aug. 1, 2003). The decision stated that all flimsy, non-durable textile costumes that are not ordinary articles of apparel are classified under subheading 9505.90.6000 (flimsy); all textile costumes that do not meet flimsy, non-durable standards (well made), or are ordinary articles of apparel are classified in chapters 61 or 62. The overall amount of finishing is such that the articles are neither flimsy in nature or construction, nor lacking in durability; your costumes are well made. The costumes consist of two or more garments. Note 14 of Section XI, of the Harmonized Tariff Schedule of the United States (HTSUS), requires that textile garments of different headings be separately classified, thus preventing classification of costumes consisting of two or more garments as sets. If a set cannot exist by application of Note 14, the articles that are packaged with the garments must be separately classified. The applicable subheading for all styles of the upper garment will be 6211.43.1092, HTSUS, which provides for “Track suits, ski-suits and swimwear: other garments: Other garments, women’s or girls’: Of man-made fibers: Other: Other.” The general rate of duty will be 16 percent ad valorem. The applicable subheading for all styles of the skirt will be 6204.53.3020, HTSUS, which provides for “Women’s or girls’…dresses, skirts, divided skirts…breeches and shorts: Skirts and divided skirts: Of synthetic fibers: Other: Other, Girls’.” The general rate of duty will be 16 percent ad valorem. The applicable subheading for all styles of the sash will be 6217.10.9530, HTSUS, which provides for “Other made-up clothing accessories; parts of garments or of clothing accessories, other than those of heading 6212: Accessories: Other, Other, Of man-made fibers.” The general rate duty will be 14.6 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 6211.43.1092, 6204.53.3020 and 6217.10.9530, 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 6211.43.1092, 6204.53.3020 and 6217.10.9530, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6211.43.1092, 6204.53.3020 and 6217.10.9530; 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 6211.43.1092, 6204.53.302 and 6217.10.9530, 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