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NY D81495

August 28, 1998

CLA-2-61:SF G03 D81495


TARIFF NO.: 6111.20.6020, 6114.20.0046, 6505.90.1540

Robert T. Stack
Tompkins & Davidson, LLP
One Astor Plaza
New York, NY 10036-8901

RE: The tariff classification of a coverall and hat from Thailand

Dear Mr. Stack:

In your letter dated August 19, 1998 you requested a tariff classification ruling, on behalf of your client, Avon Products, Inc.

Style PP 178458 consists of two items made from a fine knit fabric which you state is 100% cotton. The first item is a long sleeve, full length coverall with rib knit cuffs at the wrists and the ankles. This coverall has an opening on the left shoulder which is secured by 3 snaps and a fully opening crotch which is secured by 9 snaps on the inner leg seams. The round neckline is finished with a band of rib knit. There is a large decorative textile applique in the form of a bunny on both the front and back right side of the garment. The second item is a pullover cap made from the same fabric as the coverall. The cap has bunny ears extending from the top seam and an embroidered bunny face on the center front. You have indicated that these 2 items will be imported together as a set. Style PP 178458 comes in sizes "Small" ( 9-12 months), "Medium" (18-24 months) and

The applicable subheading for the coverall and hat set in both size Small and Medium will be 6111.20.6020, Harmonized Tariff Schedule of the United States (HTS), which provides for Babies' garments and clothing accessories, knitted or crocheted: Of cotton: Other: Other: Sets. The rate of duty will be 8.4 percent ad valorem.

The applicable subheading for the coverall in size Large will be 6114.20.0046, HTS, which provides for Other garments, knitted or crocheted: Of cotton: Coveralls, jumpsuits and similar apparel: Other: Girls'. The rate of duty will be 11.2 percent ad valorem.

The applicable subheading for the hat in size Large will be 6505.90.1540, HTS, which provides for Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed; hair-nets or any material, whether or not liner or trimmed: Other: Of cotton, flax or both: Knitted: Of cotton: Other: Other. The rate of duty will be 8.2 percent ad valorem.

The small and medium size coverall and hat set falls within textile category designation 239; the large size coverall falls within category 237, and the hat within category 359. Based upon international textile trade agreements, products of Thailand in these categories are subject to the requirement of a visa; categories 237 and 359 are subject to quota as well.

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.

In accordance with your request your samples will be returned to you under separate cover.

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.


Alice M. Rigdon
Port Director
San Francisco

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