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NY C87070

April 28, 1998

CLA-2-62:RR:NC:WA:358 C87070


TARIFF NO.: 6204.62.4065

Ms Diane Burgos
S.J. Stile Associates Ltd.
153-66 Rockaway Boulevard
Jamaica, NY 11434

RE: The tariff classification of girls' shorts with a detachable bib from Hong Kong.

Dear Ms. Burgos:

In your letter dated April 21, 1998, on behalf of CMT Fashions Inc., you requested a classification ruling.

The submitted sample, style LTP-103 is a pair of girls' woven 100% cotton blue denim shorts. The shorts feature a front and back yoke below the one metal buttoned waistband, a zippered fly front, diagonal front pockets, two rear pockets and hemmed bottoms which end at the knee. The garment also features a detachable front bib with button flap cargo pockets. The rear panels, which rise slightly above the front bib, have adjustable shoulder straps with metal hooks that attach to metal buttons on the bib front. The bib attaches to the waistband of the shorts by means of four metal buttons and buttonhole fasteners at the garment front and four similar buttons and buttonholes at the rear. According to the General Rules of Interpretations (GRI 3(b)) this garment is classified as a composite good under 6204. (HTS).

The applicable subheading for style LTP-103 will be 6204.62.4065, Harmonized Tariff Schedule of the United States (HTS), which provides for women's or girls' suits . . . bib and brace overalls, breeches and shorts (other than swimwear): trousers, bib and brace overalls, breeches and shorts: of cotton: other: other: other, shorts: girls': other. The duty rate will be 17.3 percent ad valorem.

Style LTP-103 falls within textile category designation 348. Based upon international textile trade agreements products of Hong Kong are subject quota restraints and the requirement of a visa.

The designated textile and apparel categories may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. 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 that 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 available for inspection at your local Customs office.

This merchandise may be subject to an ITC exclusion order dealing with denim garments produced by certain acid wash methods. For further information on admissibility you should contact your local Customs office. This ruling applies to the classification of the merchandise and not to its admissibility under the terms of the exclusion order.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Bruce Kirschner at 212-466-5865.


Robert B. Swierupski

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