The tariff classification of a woman’s skirt from Vietnam

N356180 December 2, 2025 CLA-2-39:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 3926.20.9050; 9903.02.69 Linda Diamant Talbots Import LLC 840 E Beechwood Rd Nixa MO 65714 RE: The tariff classification of a woman’s skirt from Vietnam Dear Ms. Diamant: In your letter dated October 20th, 2025, you requested a tariff classification ruling. Your sample will be returned. Style 254018451 is a women’s faux leather skirt. The garment is composed of cellular polyurethane plastic with a rayon woven fabric backing present merely for reinforcing purposes. The fully lined garment features a flat waistband, and a back zipper opening. Although you requested classification under subheading 6210.50.3500, Harmonized Tariff Schedule of the United States (HTSUS). Chapter 59 Note 2(a)(5) states that "Heading 5903 applies to: (a) Textile fabrics, impregnated, coated, covered or laminated with plastics…other than: (5) Plates, sheets or strip of cellular plastics, combined with textile fabric, where the textile fabric is present merely for reinforcing purposes (chapter 39)." The textile fabric backing for the garment is used merely for reinforcing the cellular plastic. Therefore, the skirt is considered made of plastic material of Chapter 39. Consequently, the applicable subheading for style 254018451 will be 3926.20.9050, HTSUS, which provides for Other articles of plastics and articles of other materials of heading 3901 to 3914: Articles of apparel and clothing accessories (including gloves, mittens, and mitts): Other: Other, Other. The rate of duty will be 5 percent ad valorem. 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 Vietnam will be subject to an additional ad valorem rate of duty of 20 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. 9903.02.69 or exclusion subheading, in addition to subheading 3926.20.9050, 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 Rosemarie Hayward at rosemariecasey.hayward@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division