The tariff classification of bib-shaped textile coverings from China

N358985 March 19, 2026 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 6307.90.9891; 9817.00.96 Mr. Alexander Mironov Mimi Blankets 30 Miranda Place Melba Australia RE: The tariff classification of bib-shaped textile coverings from China Dear Mr. Mironov: In your letter dated February 19, 2026, you requested a tariff classification ruling. Samples were provided to this office and will be retained for training purposes. The submitted sample, “Sun Protection UPF 50+ Blanket” size medium, is an oversized bib-shaped textile covering with a neck opening and rounded corners, specifically intended for use by individuals with permanent or chronic physical disabilities while using a mobility device such as a wheelchair, power chair, stroller, or tilt-in-space model. The covering is composed of a single layer of 55 percent nylon and 45 percent polyester knit fabric providing UV 50+ sun protection. The covering features an adjustable neck opening, approximately 15 inches wide, with three sets of snap buttons at each side of the neckline that allows for a more secure fit. When worn, the covering drapes approximately 11 inches from the rear neckline to the upper back and approximately 38 inches from the front neckline to the bottom front edge. It also includes two sets of bilateral self-fabric adjustable straps with snap buttons permanently sewn on both sides of the covering to secure the covering to a mobility device. You state the neckline is finished with 95 percent polyester and 5 percent cotton woven binding fabric. The covering is intended to provide full coverage from the shoulders to the ankles when in a seated position. The covering is available in two colors: blue and purple; and four sizes: Small (39 ¼ x 29 ½ inches), Medium (56 x 39 ¼ inches), Large (63 x 41 ¾ inches), and XL (70 ¾ x 41 ¾ inches). The submitted sample, “Summer Rain Poncho” size medium, is a two-piece set that includes an oversized bib-shaped textile covering with a neck opening, rounded corners, and a detachable adjustable hood, specifically intended for use by individuals with permanent or chronic physical disabilities while using a mobility device such as a wheelchair, power chair, stroller, or tilt-in-space model. The covering and detachable hood are comprised of two layers. The face side is of 100 percent polyester woven printed fabric laminated with a thermoplastic polyurethane (TPU) film. Each item is backed with 100 percent polyester woven bleached fabric. The covering features an adjustable neck opening, approximately 15 inches wide, with two sets of snap buttons at each side of the neckline that allows for a more secure fit and five snap buttons for the hood to be attached to the covering. When worn, the covering drapes approximately 23 inches from the rear neckline to the upper back and approximately 39 ½ inches from the front neckline to the bottom front edge. The covering also includes a 15 ½ inch wide zippered pocket just below the rear neckline and three sets of bilateral self-fabric adjustable straps with snap buttons permanently sewn on both sides of the covering to secure the covering to a mobility device. You state the edges of the neckline on the covering are finished with 95 percent polyester and 5 percent cotton woven binding fabric. The covering is intended to provide full coverage from the shoulders to the ankles when in a seated position. The hood has two sets of snap buttons to secure the hood under the chin. The covering and detachable hood are available in four sizes: Small (covering: 51 ¼ x 29 ½ inches and hood: 10 ¼ X 10 inches), Medium (covering: 67 ¾ x 39 ½ inches and hood: 11 ½ x 12 ½ inches), Large (covering: 74 ¾ x 41 ¾ inches and hood: 12 ½ x 13 inches ), and XL (covering: 82 ¾ x 41 ¾ inches and hood: 12 ½ x 13 inches). You have suggested that the “Sun Protection UPF 50+ Blanket” and “Summer Rain Poncho” should be classified under subheading 6301.40.1000, Harmonized Tariff Schedule of the United States, (HTSUS). We disagree. First, subheading 6301.40.1000, HTSUS is not a valid tariff number. We assume you intended to indicate subheading 6301.40.0010, HTSUS, which provides for “Blankets and traveling rugs: Other blankets and traveling rugs: Of artificial fibers.” Moreover, neither the Sun Protection Blanket nor the Rain Poncho is designed to provide warmth and do not have the essential character of blankets provided for under heading 6301, HTSUS. 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 purposes 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 together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).” Sets are classified according to the component, or components taken together, which can be regarded as conferring on the set its essential character. The “Summer Rain Poncho” consisting of a covering (heading 6307) and detachable hood (heading 6505) meet the qualification of “goods put up in sets for retail sales.” 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 covering imparts the essential character of the set. The applicable subheading for the “Sun Protection UPF 50+ Blanket” and “Summer Rain Poncho” will be 6307.90.9891, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem. In your ruling request, you suggested a secondary classification under subheading 9817.00.96, HTSUS, for the “Sun Protection UPF 50+ Blanket” and “Summer Rain Poncho” as articles specially designed or adapted for the use by the chronically or permanently disable or handicapped persons. HTSUS Chapter 98, Subchapter 17, U.S. Note 4(a), states that the term “blind or other physically or mentally handicapped persons” includes any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working. The coverings will be placed on an individual with permanent or chronic physical disabilities while using a mobility device. Based on the information supplied, it is the opinion of this office that a secondary classification will apply for the “Sun Protection UPF 50+ Blanket” and “Summer Rain Poncho” under subheading 9817.00.96, HTSUS, as “Articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing article: Other.” The rate of duty is free. We note that the retail cardboard packaging in which the sample was provided was not marked with the country of origin and the sample itself has a sewn in label with “Designed in Australia” on the front and “Made in China” on the back. Be advised, the marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. Thus, the retail packaging must reflect the country of origin as China and the sewn in label should reflect “Designed in Australia” and “Made in China” on the same face. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division