The tariff classification of men’s and women’s garments from China

N353235 September 24, 2025 CLA-2-62:OT:RR:NC:N3:357 CATEGORY: Classification TARIFF NO.: 6201.40.7511; 6202.40.7511; 9903.01.24; 9903.01.25; 9903.88.15 Nikolas Cromydas Oros Consumer LLC 140 Oxford Road Kenilworth, IL 60043 RE: The tariff classification of men’s and women’s garments from China Dear Mr. Cromydas: In your letter dated September 3, 2025, you requested a tariff classification ruling. Your samples will be returned as requested. The submitted sample, “Men’s sleeveless outerwear” is a men’s hip-length jacket constructed from both knit and woven components. The side panel on the right extending from underneath the arm to the hip is constructed of knit fabric. The balance of the garment is constructed from 91% polyester, and 9% spandex woven fabric. The fully lined sleeveless jacket features a full front opening secured by a zipper closure that extends to the top of a stand-up collar, zippered pockets below the waist, a zippered pocket on the left chest, and a hemmed bottom. The woven fabric component imparts the essential character of the garment. The submitted sample, “Women’s sleeveless outerwear” is a women’s hip-length jacket constructed from both knit and woven components. The side panel on the right extending from underneath the arm to the hip is constructed of knit fabric. The balance of the garment is constructed from 91% polyester, and 9% spandex woven fabric. The fully lined sleeveless jacket features a full front opening secured by a zipper closure that extends to the top of a stand-up collar, zippered pockets below the waist, a zippered pocket on the left chest, and a hemmed bottom. The woven fabric component imparts the essential character of the garment. You suggested classification under subheading 6211.33.9058, Harmonized Tariff Schedule of the United States (HTSUS). We disagree with your proposed classification. Based on the features and the cut of the garments, they are more specifically provided for elsewhere in the tariff. The applicable subheading for the “Men’s sleeveless outerwear” will be 6201.40.7511, HTSUS, which provides for Men’s or boys’ overcoats, carcoats, capes, cloaks, anoraks (including ski-jackets), windbreakers and similar articles (including padded, sleeveless jackets), other than those of heading 6203: Of man-made fibers: Anoraks (including ski-jackets), windbreakers and similar articles (including padded, sleeveless jackets): Other: Other: Other: Other: Other: Men’s. The rate of duty will be 27.7 percent ad valorem. The applicable subheading for the “Women’s sleeveless outerwear” will be 6202.40.7511, HTSUS, which provides for Women’s or girls’ overcoats, carcoats, capes, cloaks, anoraks (including ski-jackets), windbreakers and similar articles (including padded, sleeveless jackets), other than those of heading 6204: Of man-made fibers: Anoraks (including ski-jackets), windbreakers and similar articles (including padded, sleeveless jackets): Other: Other: Other: Other: Other: Women’s. The rate of duty will be 27.7 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 subheadings 6201.40.7511 and 6202.40.7511, 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 subheadings 6201.40.7511 and 6202.40.7511, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6201.40.7511 and 6202.40.7511, 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 subheadings 6201.40.7511 and 6202.40.7511, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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/. At the time of Entry/Entry Summary, you may be requested to verify the information for any specific shipment or product. 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 Rosemarie Hayward at rosemariecasey.hayward@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division