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HQ 964312

June 30, 2000

CLA-2 RR:CR:TE 964312 SS


TARIFF NO.: 6117.90.9020

Joanna Cheung, Trade Specialist
Hong Kong Economic and Trade Office
1520 18th Street, N.W.
Washington, D.C. 20036

RE: Classification of Knitted Collars and Cuffs; Parts of Blouses and Shirts; Subheading 6117.90.9020, HTSUSA; Not Subheading 6117.90.9080, HTSUSA

Dear Ms. Cheung:

This letter is in response to your letter dated June 23, 2000, on behalf of the consignee, Clover Garments, concerning the classification under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) of cotton knitted collars and cuffs.


The importer attempted to enter a shipment of cotton knitted collars and cuffs as clothing accessories with a visa for textile category designation 359. Upon examination of the entry documents and samples, Customs became concerned that the articles were parts of garments rather than clothing accessories. Customs contacted the broker of record and was advised that the collars and cuffs were for use in making shirts. This was consistent with Customs examination of the samples. The collars and cuffs are of a construction appropriate for polo-type shirts. Customs concluded that the collars and cuffs were classified under heading 6117.90.9020, HTSUSA, the provision for parts of cotton shirts, which requires a visa for textile category designation 339. Accordingly, the entry was rejected.


What is the proper classification for the knitted cotton collars and cuffs?


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 of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRI may then be applied. The Explanatory Notes (EN) to the Harmonized Commodity Description and Coding System, which represent the official interpretation of the tariff at the international level, facilitate classification under the HTSUSA by offering guidance in understanding the scope of the headings and GRI.

Heading 6117, HTSUSA, covers, among other things, knitted parts of garments. More specifically, subheading 6117.90.9020, HTSUSA, covers parts of cotton shirts. In your letter you suggest that the final product is undecided at this stage. This is contradictory to a statement from the broker of record. Furthermore, the physical characteristics of the collars and cuffs indicate that they are appropriate for use in making shirts. Although we agree with your contention that collars and cuffs can be made into many products other than blouses, in this particular case, we find that the collars and cuffs are for shirts.

You contend that the product should fall under “Category 359” as “other apparel.” Subheading 6117.90.9080, HTSUSA, provides for parts for garments other than sweaters, blouses, shirts, coats, jackets, trousers, breeches or shorts. The textile category designation is 359. However, since we find that the instant collars and cuffs are parts for shirts, subheading 6117.90.9080, HTSUSA, is inapplicable.

Until we receive evidence to the contrary, the physical characteristics of the collars and cuffs and statement from the broker are the best evidence available. A representation by your office at this time is not acceptable. Such representation must be made by the importer. Furthermore, we caution that if information is received that the collars and cuffs are entered by means of false information, action under 19 U.S.C. §1592 may be appropriate.


The cotton knitted collars and cuffs are classifiable in subheading 6117.90.9020, HTSUSA, textile category 339, the provision for “[o]ther made up clothing accessories, knitted or crocheted; knitted or crocheted parts of garments or of clothing accessories:

[p]arts: [o]ther, [o]f blouses and shirts: [o]f cotton.” The general column one duty rate is 15 percent ad valorem.

The designated textile and apparel category may be subdivided into parts. If so, 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 that you check, close to the time of shipment, the Status Report on Current Import Quotas (Restrain Levels), an internal issuance of the U.S. Customs Service, which 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 applicable to textile merchandise, 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
Commercial Rulings Division

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