CLA-2-73:OT:RR:NC:N5:113
Marilyn Santos
Supreme International
3000 NW 107th Avenue
Miami, FL 33172
RE: The tariff classification of collar stays and stretch collar extenders from China
Dear Ms. Santos:
In your letter dated March 25, 2025, you requested a tariff classification ruling on collar stays and stretch
collar extenders from China. Samples were submitted with your request.
The first items under consideration are described as collar stays (style F15ER003). The collar stays are made
of brushed stainless steel and are between two and three inches in length. During use, the collar stays are
placed into a sleeve within the underside of a shirt collar. You state that the collar stays maintain collar shape
by preventing the collar from curling and wrinkling.
The second items under consideration are described as stretch collar extenders (style F15ER013). The stretch
collar extenders are aluminum buttons with a circular area of black enamel on the front indentation. In
addition, an expanding stainless steel coil is threaded through a loop in the aluminum body of the button.
During use, the aluminum button is inserted through a button opening on a shirt. Then, the expanding
stainless steel coil is secured around a corresponding shirt button. This creates a connection and closes the
shirt. Due to the expanding nature of the coil, a shirt can be closed while offering users extra space for
movement without altering the shirt.
The applicable subheading for the collar stays will be 7326.90.8688, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Other articles of iron or steel: Other: Other: Other: Other: Other.
The rate of duty will be 2.9% ad valorem.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7326.90.8688,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
Please note that derivative steel products admitted to a U.S. foreign trade zone under “privileged foreign
status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to
additional duties under heading 9903.81.93, HTSUS.
The applicable subheading for the stretch collar extenders will be 9606.22.0000, HTSUS, which provides for
Buttons, press-fasteners, snap-fasteners and press-studs, button molds and other parts of these articles; button
blanks: Buttons: Of base metal, not covered with textile material. The rate of duty will be free.
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 subheadings 7326.90.8688 and 9606.22.0000, 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. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. The collar stays fall within an
excepted subheading, but the stretch collar extenders do not. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.33 and 9903.01.63, in addition to
subheadings 7326.90.8688 and 9606.22.0000, HTSUS, respectively, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 7326.90.8688, and 9606.22.0000, HTSUS, unless specifically excluded, are subject to an
additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99
subheading, i.e., 9903.88.03, in addition to subheadings 7326.90.8688, and 9606.22.0000, 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/programs-administration/trade-remedies, respectively.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division