CLA-2-61:OT:RR:NC:N3:358
Angie McDaniel
Sugartown Worldwide, LLC (dba Lilly Pulitzer)
752 S. Victory Drive
Lyons, GA 30436
RE: The tariff classification of garments from India
Dear Ms. McDaniel:
In your letter dated February 24, 2025, you requested a tariff classification ruling. The submitted samples will be returned.
Style 020214 consists of a girl’s blouse constructed of 100% cotton knit fabric and a girl’s legging constructed of 95% cotton, 5% spandex. The loose-fitting blouse extends from the shoulders to below the waist and measures at least 10 or more stitches per linear centimeter measured in both directions. The garment features a collar, a partial front opening with a three-button closure, two self-fabric ruffles affixed by an elastic waistband at the bottom and long hemmed sleeves. The girl’s legging features a covered elastic waistband, hemmed leg openings and a bow on each ankle. The garments will be imported in girls’ sizes XS-XL.
Style 020215 consists of an infant’s blouse constructed of 100% cotton knit fabric and an infant’s legging constructed of 95% cotton, 5% spandex. The loose-fitting blouse extends from the shoulders to below the waist and measures at least 10 or more stitches per linear centimeter measured in both directions. The garment features a collar, a partial front opening with a three-button closure, two self-fabric ruffles affixed by an elastic waistband at the bottom and long hemmed sleeves. The infant’s legging features a covered elastic waistband, hemmed leg openings and a bow on each ankle. The garments will be imported in infant’s sizes 3-6 months and 12-24 months.
Note 14 to Section XI, Harmonized Tariff Schedule of the United States (HTSUS), requires that textile garments of different headings be separately classified. The girl’s garments are classified under two different headings thus preventing classification of style 020214 as a set.
As for style 020215, in heading 6111, HTSUS, the term “sets” means two or more different garments of headings 6111, 6209 or 6505 imported together, of corresponding sizes and intended to be worn together by the same person. The infant upper body garment and infant legging, both classifiable under subheading 6111.30.50, HTSUS, meet the terms of Additional U.S. Note 1 to Chapter 61, HTSUS, as a “set.”
The applicable subheading for the blouse of style 020214 will be 6106.10.0030, HTSUS, which provides for “Women’s or girl’s blouses and shirts, knitted or crocheted: Of cotton: Girls’: Other.” The rate of duty will be 19.7 percent ad valorem.
The applicable subheading for the legging of style 020214 will be 6104.62.2026, HTSUS, which provides for “Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: Trousers, bib and brace overalls, breeches and shorts: Of cotton: Other: Trousers and breeches: Girls’: Other: Containing 5 percent or more by weight of elastomeric yarn or rubber thread.” The rate of duty will be 14.9 percent ad valorem.
The applicable subheading for style 020215 will be 6111.20.6020, HTSUS, which provides for “Babies’ garments and clothing accessories, knitted or crocheted: Of cotton: Other: Other: Sets.” The rate of duty will be 8.1 percent ad valorem.
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 Katherine Souffront at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division