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

N353268 October 1, 2025 CLA-2-61:OT:RR:NC:N3:357 CATEGORY: Classification TARIFF NO.: 6101.30.2010; 6110.30.3053; 6110.30.3059; 6201.40.7000; 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 4, 2025, you requested a tariff classification ruling. Your samples will be returned as requested. The submitted sample, “Men’s Atmos Jacket” is a men’s hip-length jacket constructed from 91% polyester, and 9% spandex knit fabric. The jacket features a full front opening secured by a zipper closure that extends to the top of a stand-up collar, a hood, zippered pockets below the waist, a zippered pocket inside the left chest, long tapered sleeves, and a finished bottom. The submitted sample, “Astra Hoody” is a women’s cut and sewn lined pullover with an outer shell constructed of 91% polyester, and 9% spandex knit fabric. The fabric measures 34 stitches per two per centimeters counted in the horizontal direction. The garment is of three-ply construction throughout and features a partial front opening with a contrasting color zippered closure, a self-fabric hood, long, raglan sleeves with self-fabric cuffs, a logo at the bottom of the left sleeve, thumbholes in each cuff, a pouch pocket below the waist with side seam zippers, a hanger loop at the rear neckline, a trademark logo at the upper right side rear panel, and a hemmed bottom with a curved tail. The submitted sample, Style “Horizon Quarter Zip 3.0,” is a men’s pullover garment constructed from 94 polyester and 6 percent spandex knit fabric. The outer surface of the garment’s fabric measures more than nine stitches per two centimeters in the direction the stitches were formed. The snug-fitting garment features a partial front opening with a zippered closure that zips through a self-fabric, stand-up collar; long, hemmed sleeves with thumb holes; a vertical pocket with a zippered closure on the left chest; and a straight, hemmed bottom. Although portions of the garment feature insulation that you state is for cold weather protection, examination in this office reveals that the garment is not designed to be worn over all other clothing for protection against the elements. The submitted sample, “Men’s Voyager Jacket” is a men’s jacket constructed from 85% polyamide, and 15% elastane woven fabric. The lined jacket features a full front opening secured with six left-over-right snap closure, a pointed collar, a left zippered chest pocket, pockets below the waist secured with hidden magnet closure, long sleeves with snap cuffs, and a hemmed bottom. The submitted sample, “Female Voyager Jacket” is a women’s jacket constructed from 85% polyamide, and 15% elastane woven fabric. The lined jacket features a full front opening secured with a zipper closure that extends to the top of a stand-up collar and an inner storm flap, a zippered pocket inside the left chest, pockets below the waist secured with hidden magnet closure, long sleeves with snap cuffs, and hemmed bottom. The submitted sample, “Men’s Itinerant 3.0” is a men’s hip-length jacket constructed from 91% polyester, and 9% spandex woven fabric. The jacket features a full front opening secured by a zipper closure that extends to the top of a stand-up collar, unsecured pockets below the waist, long tapered sleeves, and a finished bottom. In your letter, you state the “Men’s Itinerant 3.0” is Durable Water Repellent (DWR) treated; however, you did not provide documentation to support your claim. We have not confirmed the results in our own laboratory, although the CBP officer handling the transaction may choose to do so at the time of importation. You suggested classification of the Men’s Atmos Jacket, Female Astra Jacket, Men’s Voyager Jacket, Female Voyager Jacket, Men’s Itinerant 3.0, and Men’s Horizon Quarter Zip 3.0 under subheading 6211.33.9058, Harmonized Tariff Schedule of the United States (HTSUS). We disagree with your proposed classification. Based on the construction, features and cut of the garments, they are more specifically provided for elsewhere in the HTSUS. If the “Men’s Itinerant 3.0” passes the water resistant test as specified in HTSUS, Chapter 62, Additional U.S. Note 2, then the applicable subheading for the “Men’s Itinerant 3.0” will be 6201.40.7000, 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: Water resistant. The rate of duty will be 7.1 percent ad valorem. If the “Men’s Itinerant 3.0” does not pass the water resistant test, the applicable subheading for the “Men’s Itinerant 3.0”, and the “Men’s Voyager Jacket” 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 “Woman’s Astra Hoody” will be 6110.30.3059, HTSUS, which provides for Sweaters, pullovers, sweatshirts, waistcoats (vests) and similar articles, knitted or crocheted (con.): Of man-made fibers: Other: Other: Other: Other: Women’s or girls’: Other. The general rate of duty will be 32 percent ad valorem. The applicable subheading for Style “Horizon Quarter Zip 3.0” will be 6110.30.3053, HTSUS, which provides for: Sweaters, pullovers, sweatshirts, waistcoats (vests) and similar articles, knitted or crocheted: Of man-made fibers: Other: Other: Other: Other: Other: Men’s or boys’: Other. The general rate of duty will be 32 percent ad valorem The applicable subheading for the “Men’s Atmos Jacket” will be 6101.30.2010, HTSUS, which provides for Men’s or boys’ overcoats, carcoats, capes, cloaks, anoraks (including ski-jackets), windbreakers and similar articles, knitted or crocheted, other than those of heading 6103: Of man-made fibers: Other: Other: Men’s. The rate of duty will be 28.2 percent ad valorem. The applicable subheading for the “Female Voyager Jacket” 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 subheading 6101.30.2010, 6110.30.3053, 6110.30.3059, 6201.40.7000, 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. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25 or exclusion subheading, in addition to subheading 6101.30.2010, 6110.30.3053, 6110.30.3059, 6201.40.7000, 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 6101.30.2010, Toni, Maryalice, 6201.40.7000, 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 subheading, 6101.30.2010, 6110.30.3053, 6110.30.3059, 6201.40.7000, 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