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NY F81913

March 7, 2000

CLA-2-61:RR:NC:TA:359 F81913


TARIFF NO.: 6110.20.2075

Mr. Arthur W. Bodek
Akin, Gump, Strauss, Hauer & Feld, LLP
590 Madison Ave., 20th Floor
New York, NY 10022

RE: The tariff classification of a woman’s knitted pullover from Cambodia or Russia

Dear Mr. Bodek:

In your letter dated January 31, 2000, submitted on behalf of your client, Miss Erika, Inc., 1407 Broadway, New York, NY, 10018, you requested a tariff classification ruling.

The sample which you submitted is returned as requested. Style No. 70192 is a woman’s knitted pullover with long sleeves and a V-shaped neckline. You describe it as “a traditional reversible garment such that either surface may be worn as the inside or the outside”. We note that the pullover consists of two layers of knitted fabric for the torso and four layers for the sleeves which are cut into the shapes needed for a long sleeved pullover, and which are then sewn together. At the outer edges of each layer of fabric, that is, at its bottom, neckline, shoulders, side seams, sleeve seams or sleeve ends, each one of the fabric layers is turned into its opposite layer and the edges are sewn together. An inspection of the finished pullover reveals that it is a true reversible garment insofar as it can be worn with either layer of fabric showing as its outer fabric surface. The fiber content of each fabric layer is 60% cotton, 40% polyester. The outer surface of the knitted fabric of each layer measures more than nine stitches per two centimeters, measured in the direction in which the stitches were formed.

The applicable subheading for Style No. 70192, the pullover, will be 6110.20.2075, Harmonized Tariff Schedule of the United States (HTS), which provides for sweaters, pulloversand similar articles, knitted or crocheted: of cotton: other: other: other, women’s. The duty rate will be 18.2% ad valorem.

The pullover falls within textile category designation 339. Based upon international textile trade agreements products of Cambodia are subject to quota and the requirement of a visa. Products of Russia are not subject to quota or visa requirements.

You also inquire about the country of origin marking label that must be placed on the pullover when it is imported into the commerce of the United States. Specifically, you ask if marking by means of a hangtag securely affixed in the neck area is acceptable in view of the reversible nature of the pullover. We note that on several occasions Customs headquarters has ruled favorably concerning the acceptable marking of reversible garments when the proposed marking was in accordance with your suggested marking for the pullover which you submitted. Most recently in their decision, HQ561255, January 29, 1999, headquarters decided that a woman’s reversible sweater could be marked with a hangtag affixed in the neck area setting forth the country of origin, fiber content and the company name and/or RN number, provided that the marking is legible, conspicuous and permanent. We, therefore find acceptable your proposal that the marking label be in the form of a hangtag securely affixed in the neck area of the submitted sample.

To ensure compliance with the Textile Fiber Products Identification Act we suggest that you contact the Federal Trade Commission for information regarding the use of the proposed hangtags. Customs does not issue rulings or decisions on FTC guidelines. The address of the FTC is – Federal Trade Commission, 6th and Pennsylvania, NW, Washington, D.C. 20580.

The designated textile and apparel categories and their quota and visa status are the result of international agreements that are subject to frequent renegotiations and changes. To obtain the most current information, we suggest that you check, close to the time of shipment, the U.S. Customs Service Textile Status Report, an internal issuance of the U.S. Customs Service, which is available at the Customs Web site at www.customs.gov. In addition, 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 and should also be verified at the time of shipment.

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 Mike Crowley at 212-637-7077.


Robert B. Swierupski

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