The tariff classification of textile bib-shaped coverings with a detachable hood from China

N358986 March 19, 2026CLA-2-63:OT:RR:NC:N3:349 CATEGORY: Classification TARIFF NO.: 6307.90.9891; 9817.00.96 Mr. Alexander MironovMimi Blankets30 Miranda PlaceMelba AustraliaRE: The tariff classification of textile bib-shaped coverings with a detachable hood from ChinaDear Mr. Mironov:In your letter dated February 19, 2026 , you requested a tariff classification ruling. Samples were provided tothis office and will be retained for training purposes.The submitted sample, “Minky Plush Blanket,” size medium, is a two-piece set that includes an oversizedbib-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 amobility device such as a wheelchair, power chair, stroller, or tilt-in-space model. The covering anddetachable hood are comprised of two layers. The face side is of 100 percent polyester knit printed minkyfabric.Each item is backed with 100 percent polyester knit dyed minky dot fabric. The covering features an adjustable neck opening, approximately 15 inches wide, with two sets of snap buttons at each side of theneckline that allows for a more secure fit and three snap buttons for the hood to be attached to the covering. When worn, the covering drapes approximately 11 ½ inches from the rear neckline to the upper back andapproximately 39 ½ inches from the front neckline to the bottom front edge.The covering also includes two sets of bilateral self-fabric adjustable straps with snap buttons permanently sewn on both sides of thecovering to secure the covering to a mobility device. You state the edges of the neckline on the covering arefinished with 95 percent polyester and 5 percent cotton woven binding fabric. The covering is intended toprovide full coverage from the shoulders to the ankles when in a seated position. The adjustable hoodfeatures three snap buttons at the crown that allow the depth of the hood to be shortened, and an elasticizedcord threaded around the face to allow the hood to be cinched around the face.The covering and detachable hood are available in four sizes: Small (covering: 39 ½ x 29 ½ inches and hood: 10 ¼ X 10 inches), Medium(covering: 56 x 39 ½ inches and hood: 11 ½ x 12 ½ inches), Large (covering: 63 x 42 ½ inches and hood: 12½ x 13 inches ), and XL (covering: 71 x 42 ½ inches and hood: 12 ½ x 13 inches). The submitted sample, “Waterproof Minky Blanket,” size medium, is a two-piece set that includes anoversized bib-shaped textile covering with a neck opening, rounded corners and a detachable adjustablehood, specifically intended for use by individuals with permanent or chronic physical disabilities while usinga mobility device such as a wheelchair, power chair, stroller, or tilt-in-space model. The covering anddetachable hood are comprised of two layers. The face side is of 100 percent cotton woven printed fabriclaminated with a thermoplastic polyurethane (TPU) film.Each item is backed with 100 percent polyester knit dyed minky pile dot fabric. The covering features an adjustable neck opening, approximately 16 ½inches wide, with two sets of snap buttons at each side of the neckline that allows for a more secure fit andthree snap buttons for the hood to be attached to the covering. When worn, the covering drapesapproximately 23 inches from the rear neckline to the upper back and approximately 39 ½ inches from thefront neckline to the bottom front edge.The covering 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 mobilitydevice. You state the edges of the neckline on the covering are finished with 95 percent polyester and 5percent cotton woven binding fabric. The covering is intended to provide full coverage from the shoulders tothe ankles when in a seated position. The adjustable hood features three snap buttons at the crown that allow the depth of the hood to be shortened. The covering and detachable hood are available in four sizes: Small(covering: 51 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). The submitted sample, “Berber Blanket,” size medium, is a two-piece set that includes an oversizedbib-shaped textile covering with a neck opening, rounded corners, and a detachable hood, specificallyintended for use by individuals with permanent or chronic physical disabilities while using a mobility devicesuch as a wheelchair, power chair, stroller, or tilt-in-space model. The covering and detachable hood arecomprised of two layers. The face side is of 100 percent polyester knit printed minky fabric.Each item is backed with 100 percent polyester knit sherpa pile fabric. The covering features an adjustable neck opening,approximately 17 inches wide, with two sets of snap buttons at each side of the neckline that allows for amore secure fit and five snap buttons for the hood to be attached to the covering. When worn, the coveringdrapes approximately 11 ½ inches from the rear neckline to the upper back and approximately 39 ½ inchesfrom 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 two sets of bilateral self-fabric adjustable straps with snap buttonspermanently 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 wovenbinding fabric. The covering is intended to provide full coverage from the shoulders to the ankles when in aseated 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: 39 ¼ x 29 ½ inches and hood: 10 ¼ X 10 inches), Medium (covering: 56 x 39 ¼ inches and hood: 11 ½ x 12 ½ inches), Large (covering: 63 x 42 ½inches and hood: 12 ½ x 13 inches ), and XL (covering: 70 ¾ x 42 ½ inches and hood: 12 ½ x 13 inches). The submitted sample, “Waterproof Berber Blanket,” size medium, is a two-piece set that includes anoversized bib-shaped textile covering with a neck opening, rounded corners, and a detachable hood,specifically intended for use by individuals with permanent or chronic physical disabilities while using amobility device such as a wheelchair, power chair, stroller, or tilt-in-space model. The covering anddetachable hood are comprised of two layers. The face side is of 100 percent cotton woven printed fabriclaminated with a thermoplastic polyurethane (TPU) film.Each item is backed with 100 percent polyester knit sherpa pile fabric. The covering features an adjustable neck opening, approximately 16 ½ inches wide,with two sets of snap buttons at the neckline that allows for a more secure fit and five snap buttons for thehood to be attached to the covering. When worn, the covering drapes approximately 23 inches from the rearneckline 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 two sets ofbilateral self-fabric adjustable straps with snap buttons permanently sewn on both front sides of the coveringto secure the covering to a mobility device. You state the edges of the neckline on the covering are finishedwith 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 buttonsto 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 ¼ inches andhood: 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 ½ x 41 ¾ inches and hood: 12 ½ x 13 inches). You have suggested that the “Minky Plush Blanket,” “Waterproof Minky Blanket,” “Berber Blanket,” and“Waterproof Berber Blanket” should be classified under subheading 6301.90.1000, Harmonized TariffSchedule of the United States, (HTSUS). We disagree. First, subheading 6301.90.1000, HTSUS is not avalid tariff number. We assume you intended to indicate subheading 6301.90.0010, HTSUS, which providesfor “Blankets and traveling rugs: Other blankets and traveling rugs: Of artificial fibers.” Secondly, althoughthe coverings are made of pile material that provides warmth, in our opinion, the design of these itemsexceeds the character of a blanket of heading 6301, HTSUS.The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute theofficial 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 tomean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in differentheadings; (b) consist of products or articles put together to meet a particular need or carry out a specificactivity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes orcases or on boards).” Sets are classified according to the component, or components taken together, whichcan be regarded as conferring on the set its essential character. The “Minky Plush Blanket,” “Waterproof Minky Blanket,” “Berber Blanket,” and “Waterproof BerberBlanket” consisting of a covering (heading 6307) and detachable hood (heading 6505) meet the qualificationof “goods put up in sets for retail sales.” The set consists of at least two different articles which are, primafacie, 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 “Minky Plush Blanket,” “Waterproof Minky Blanket,” “Berber Blanket,”and “Waterproof Berber Blanket” will be 6307.90.9891, HTSUS, which provides for “Other made uparticles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent advalorem.In your ruling request, you suggested a secondary classification under subheading 9817.00.96, HTSUS, forthe “Minky Plush Blanket,” “Waterproof Minky Blanket,” “Berber Blanket,” and “Waterproof BerberBlanket” as articles specially designed or adapted for the use by the chronically or permanently disable orhandicapped persons. HTSUS Chapter 98, Subchapter 17, U.S. Note 4(a), states that the term “blind or otherphysically or mentally handicapped persons” includes any person suffering from a permanent or chronicphysical or mental impairment which substantially limits one or more major life activities, such as caring forone’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working. Thecovering will be placed on an individual with permanent or chronic physical disabilities while using amobility device. Based on the information supplied, it is the opinion of this office that a secondaryclassification will apply for the “Minky Plush Blanket,” “Waterproof Minky Blanket,” “Berber Blanket,” and“Waterproof Berber Blanket” under subheading 9817.00.96, HTSUS, as “Articles specially designed oradapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts andaccessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designedThe rate of duty is free.or adapted for use in the foregoing article: Other.” We note that the retail cardboard packaging in which the sample was provided was not marked with thecountry 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) importedinto the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of thearticle (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. theEnglish 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 isconsidered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read itwithout 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 providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Kristine Dodge at Kristine.Dodge@cbp.dhs.gov. Sincerely, (for)James ForkanDesignated Official Performing the Duties of the Division DirectorNational Commodity Specialist Division