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HQ 958382

October 27, 1995

CLA-2 R:C:T 958382 CMR


TARIFF NO.: 6206.30.3040

Mr. Rommel Redito
The Apparel Group Ltd.
1370 Avenue of the Americas
New York, New York 10019

RE: Modification of District Decision 810163 of June 2, 1995; Classification of a woven blouse with two detachable collars; Composite good; Set

Dear Mr. Redito:

On June 2, 1995, Customs issued District Decision (DD) 810163 to you. In that ruling, Customs classified a women's woven blouse with two detachable collars as follows: the blouse and one collar were classified as a composite good; and, the other collar was separately classified. We have had occasion to review that ruling and found it to be partially in error. Therefore, we are taking this action to correct the error.

Pursuant to section 625, Tariff Act of 1930 (19 U.S.C. 1625), as amended by section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement Implementation Act, Pub. L. 103-182, 107 Stat. 2057, 2186 (1993) (hereinafter section 625), notice of the proposed modification of DD 810163 was published September 27, 1995, in the Customs Bulletin, Volume 29, Number 39.


The merchandise at issue, style 401136, consists of a women's woven blouse and two detachable collars. All three items are manufactured from 55 percent cotton/45 percent polyester woven fabric. The blouse features a band collar with five buttons sewn on the inside of the collar for attaching the detachable collars. The blouse also has long sleeves with button cuffs, a full front opening secured by six concealed buttons and one visible button, and a curved, hemmed bottom. The detachable collars each have five buttonholes that correspond to the buttons on the blouse collar. The merchandise is from Thailand.


What is the proper classification of the woven blouse and two detachable collars?


Classification of goods under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) is governed by the General Rules of Interpretation (GRIs). GRI 1 provides that "classification shall be determined according to the terms of the headings and any relative section or chapter notes and, provided such headings or notes do not otherwise require, according to [the remaining GRIs taken in order]."

As stated above, we believe DD 810163 is only partially in error. Classification of the woven blouse and one detachable collar as a composite good is correct. The items meet the definition of a composite good provided by the Explanatory Notes (EN) to the Harmonized Commodity Description and Coding System. Although not legally binding, the EN are the official interpretation of the tariff at the international level.

According to the EN, a composite good made up of different components includes:
not only those in which the components are attached to each other to form a practically inseparable whole but also those with separable components, provided these components are adapted one to the other and are mutually complementary and that together they form a whole which would not normally be offered for sale in separate parts.

In this case, the blouse and each individual collar are separable components that are adapted to each other, are mutually complementary, and together form a whole that would normally not be sold as separate parts. Although the blouse is complete and is of a type that would be sold separately, the attachable collars clearly would not have any use without the blouse with which they were designed to be worn.

It is Customs view that the blouse and one collar form a composite good. The Explanatory Notes describe separable components of composite goods as "together forming a whole." In this case, one collar attached to the blouse forms a whole, i.e., a blouse with a pointed collar. The remaining collar is separate from "the whole".

Since only one collar may be classified with the blouse as a composite good, the classification of the second collar must be decided. It is here we believe we erred in DD 810163. In DD -3-

810163 Customs classified the second collar separately under subheading 6217.10.9010, HTSUSA, as a clothing accessory. This office believes it is properly considered part of a set together with the composite article (blouse and one collar). In regard to goods put up in sets for retail sale, the Explanatory Notes defines sets as 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 up 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.

The composite blouse and collar are classifiable in heading 6206, HTSUSA, which is the classification heading applicable to the blouse. This is based on a determination that the blouse imparts the essential character to the composite. The extra collar is classifiable in heading 6217, HTSUSA. Following the definition of sets stated above, we have at least two articles (the composite blouse and extra collar) which are classifiable in different headings (6206 and 6217). The items are put together to meet a particular need, i.e., for the purpose of clothing a person, and they are put up in a manner suitable for sale directly to users without repacking. We believe the blouse imparts the essential character to the set and thus, the set is classifiable under the provision applicable to the composite which is the heading for the woven blouse, heading 6206, HTSUSA.


Based upon the above analysis, the woven blouse and two detachable collars are classified as a set consisting of a composite good (the blouse and one collar) and the remaining collar. As the woven blouse imparts the essential character of the composite, as well as the set, all items are classified with the blouse in subheading 6206.30.3040, HTSUSA, textile category 341, dutiable at 16.3 percent ad valorem. As part of a composite good, one collar is included with the blouse for textile category purposes.

If classified separately, the remaining collar would be classified as a clothing accessory of cotton, in subheading 6217.10.9010, HTSUSA, textile category 359. As part of a set, the remaining collar is subject to textile quota/visa restraints for category 359.

DD 810163 is modified to accord with the above. In accordance with section 625, this ruling will become effective 60 -4-
days after its publication in the Customs Bulletin. Publication of rulings or decisions pursuant to section 625 does not constitute a change of practice or position in accordance with section 177.10(c)(1), Customs Regulations (19 CFR 177.10(c)(1)).

The designated textile and apparel category may be subdivided into parts. If so, the visa and quota requirements applicable to the subject merchandise may be affected. Since part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes, to obtain the most current information available, we suggest you check, close to the time of shipment, the Status Report On Current Import Quotas (Restraint Levels), an internal issuance of the U.S. Customs Service which is updated weekly and is available for inspection at your local Customs office.

Due to the changeable nature of the statistical annotation (the ninth and tenth digits of the classification) and the restraint (quota/visa) categories, you should contact your local Customs office prior to importation of this merchandise to determine the current status of any import restraints or requirements.


John Durant, Director
Tariff Classification Appeals Division

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