The tariff classification of a textile baby carrier cover with a hat from China

N353191 September 19, 2025 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 6307.90.9891: 9903.01.24; 9903.01.25; 9903.88.15 Ms. Kim Benedetto Seasons USA Inc. 2041 Genesee Street Utica, NY 13501 RE: The tariff classification of a textile baby carrier cover with a hat from China Dear Ms. Benedetto: In your letter dated September 2, 2025, you requested a tariff classification ruling on behalf of your client, Seasons HK Ltd. A sample of the product was provided to this office and will be retained for training purposes. The sample, item #OEM27-0746, described as an “Infant Bat Carrier Costume,” consists of a textile baby carrier cover and a baby’s hat. The carrier cover is designed to be attached to a baby carrier and intended to act as a baby’s costume during Halloween. The item is not meant to hold the baby. The carrier cover is constructed of two layers: a front layer of 100 percent polyester knitted micro minky plush dyed fabric and a back layer (touches the baby carrier) of 100 percent polyester woven satin dyed fabric. The U-shaped carrier cover measures 14 inches in width by 17 inches in height. The cover features two bat wings composed of three layers: a single layer of 100 percent polyester non-woven felt material is sandwiched between two layers of 100 percent polyester woven satin, dyed, fabric, sewn to the front layer of fabric. The cover also features two shoulder straps and two waist straps with hook-and-loop fasteners for securing the cover to a baby carrier. The baby’s hat consists of three layers: an outer layer of 100 percent polyester knitted micro minky plush dyed black fabric, a middle layer of 100 percent polyester fiber filling, and an inner layer of 100 percent polyester woven satin dyed teal fabric. The hat measures 10 inches in length by 7 inches in height and has an elastic band sewn around the opening to help secure it to the baby’s head. It is decorated with two ears, embroidered eyes, a nose, a mouth, and two white fangs. The two items will be packaged together with a bellyband. The Explanatory Notes (Ens) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI), 3(b) provides: “for the purpose of this Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are prima facie, classifiable in different headings; (b) consist of products or articles put up together to meet a particular need or carry out a specific activity; (c) are put up in a manner suitable for sale directly to users without repacking (e.g. in boxes or cases or on board).” Sets are classified according to the component, or components taken together, which can be regarded as conferring on the set as a whole its essential character. The baby carrier cover (heading 6307) and hat (heading 6505) meet the qualifications of "goods put up in sets for retail sale." The set consists of at least two different articles which are, prima facie, classifiable in different headings. They are put up together to meet a particular need or carry out a specific activity, and they are packed for sale directly to users without repackaging. The textile cover imparts the essential character of the set. The applicable subheading for the carrier cover will be 6307.90.9891, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The general rate of duty will be 7 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 6307.90.9891, 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 from 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 6307.90.9891, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6307.90.9891, 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 6307.90.9891, 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 Kristine Dodge at kristine.dodge@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division