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

N353270 October 2, 2025 CLA-2-62:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 6210.20.5020; 6210.30.5020; 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 jackets 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 Orion Parka 3.0” is a men’s hip-length jacket constructed from 91% polyester, and 9% spandex woven fabric visibly coated with polyurethane on the inner surface. The jacket has a stand-up collar and a hood with a tightening drawcord. The fully lined jacket features full front opening secured by a zipper closure extending to the top of the collar and an overlapping flap with four hook and loop fasteners that cover the zipper area. The jacket includes sealed seams, long sleeves with a knit fabric inner storm cuff, two vertical chest pockets with flaps secured by zipper closures, two vertical front pockets with flaps secured by zipper closures at the waist, and a hemmed bottom with a rear vent. The submitted sample, “Female Orion Parka 3.0” is a women’s hip-length jacket constructed from 91% polyester, and 9% spandex woven fabric visibly coated with polyurethane on the inner surface. The jacket has a stand-up collar and a hood with a tightening drawcord. The fully lined jacket features full front opening secured by a zipper closure extending to the top of the collar and an overlapping flap with five hook and loop fasteners that cover the zipper area. The jacket includes sealed seams, long sleeves with a knit fabric inner storm cuff, two vertical chest pockets with flaps secured by zipper closures, two vertical front pockets with flaps secured by zipper closures at the waist, and a hemmed bottom with two rear vents. In your letter, you state “Men’s Orion Parka 3.0”, and “Female Orion Parka 3.0” are water resistant and meet the definition of recreational performance outerwear. In your letter, you provided an independent laboratory test report showing that the fabric is water resistant as specified in additional U.S. note 2 to chapter 62. You did not provide documentation showing that the sealed seams are water resistant in accordance with the current version of AATCC Test Method 35 as required in additional U.S. note 3(b)(ii) to chapter 62, and we have not tested the seams in our own laboratory. Customs and Border Protection may choose to do so at the time of importation. Regarding the claim of recreational performance outerwear, per additional U.S. note 3 to chapter 62 the term ‘'recreational performance outerwear” means trousers (including, but not limited to, ski or snowboard pants, and ski or snowboard pants intended for sale as parts of ski-suits), coveralls, bib and brace overalls, jackets (including, but not limited to, full zip jackets, ski jackets and ski jackets intended for sale as parts of ski-suits), windbreakers and similar articles (including padded, sleeveless jackets), the foregoing of fabrics of cotton, wool, hemp, bamboo, silk or manmade fibers, or a combination of such fibers; that are either water resistant within the meaning of additional U.S. note 2 to this chapter or treated with plastics, or both; with critically sealed seams, and with 5 or more of the following features (as further provided herein): (i) insulated for cold weather protection; (ii) pockets, at least one of which has a zippered, hook and loop, or other type of closure; (iii) elastic, drawcord or other means of tightening around the waist or leg hems, including hidden leg sleeves with a means of tightening at the ankle for trousers and tightening around the waist or bottom hem for jackets; (iv) venting, not including grommet(s); (iv) articulated elbows or knees; (v) reinforcement in one of the following areas: the elbows, shoulders, seat, knees, ankles or cuffs; (vi) weatherproof closure at the waist or front; (vii) multi-adjustable hood or adjustable collar; (ix) adjustable powder skirt, inner protective skirt or adjustable inner protective cuff at sleeve hem; (x) construction at the arm gusset that utilizes fabric, design or patterning to allow radial arm movement; or (xi) odor control technology We have reviewed the garments and found that they are one of the listed garments, are constructed from one of the listed fibers, and potentially contains critically sealed seams in the interlining. Both garments are eligible for classification as recreational performance outerwear. The garments are made of fabric treated with plastics within the meaning of Additional U.S. Note 3(b)(i) which states, “The term ‘treated with plastics’ refers to textile fabrics impregnated, coated, covered or laminated with plastics, as described in Note 2 to Chapter 59.” In addition, the garments are made of a man-made fiber, contain sealed seams, and includes the following five features: Pockets, at least one of which has a zipper, A back vent, Reinforcement at the elbows, Weatherproof closure in the form of a storm flap, and A multi-adjustable hood. In your letter, you suggest classified of these garments under subheading 6202.40.45, Harmonized Tariff Schedule of the United States (HTSUS); however, per Note 6 to Chapter 62, HTSUS, states, “Garments which are, prima facie, classifiable both in heading 6210 and in other headings of this chapter, excluding heading 6209, are to be classified in heading 6210.” The applicable subheading for “Men’s Orion Parka 3.0” will be 6210.20.5020, HTSUS, which provides for Garments, made up of fabrics of heading 5602, 5603, 5903, 5906, or 5907: Other garments of the type described in heading 6201: Of man-made fibers: other: Anoraks (including ski-jackets), windbreakers and similar articles: Recreational performance outerwear. The rate of duty will be 7.1% ad valorem. The applicable subheading for “Female Orion Parka 3.0” will be 6210.30.5020, HTSUS, which provides for Garments, made up of fabrics of heading 5602, 5603, 5903, 5906, or 5907: Other garments, of type described in heading 6202: Of man-made fibers: Other: Anoraks (including ski-jackets), wind breakers and similar articles: Recreational performance outerwear. The rate of duty will be 7.1% 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 6210.20.5020, and 6210.30.5020, 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 6210.20.5020, and 6210.30.5020, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6210.20.5020, and 6210.30.5020, 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, 6210.20.5020, and 6210.30.5020, 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