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HQ 966390

July 3, 2003

CLA-2 RR:CR:TE 966390 TMF


TARIFF NO.: 6102.10.0000

Bernadette Placido
Customs Compliance
QVC, Inc.
1200 Wilson Drive
West Chester, Pennsylvania 19380-4262

RE: Classification and Country of Origin of Women's Knitted 100% Wool, Hooded Long Coat

Dear Ms. Placido:

This is in response to your letter of March 27, 2003, in which your company requested a binding classification ruling and country of origin determination on a ladies’ knitted wool, hooded long coat under the Harmonized Tariff Schedule of the United States Annotated (hereinafter referred to as “HTSUSA”). Your request along with the subject coat and eleven component parts were submitted to our office for our reply.


In your submission, you described the subject article (identified as QVC item number A97933) as a “ladies knit, 100% wool hooded long coat”, made from wool yarn originating from Jiangsu, China. You also indicated that the ports of entry will be Norfolk, New York, Baltimore or Los Angeles. In email correspondence, you described the article as follows:

Women's knitted 100% boiled wool, hooded sweater coat is double breasted with seven dyed to match buttons and two front patch pockets.

The coat is finished with contrast trim along the hood, front closure, bottom hem and on turn back cuffs. One extra button is included. Available in Black/Brown, Charcoal/Taupe, Navy/Olive, Camel/Ivory, Red/Black. Sizes: S(6-8), M(10-12), L(14-16), 1X(18-20), 2X(22-24), 3X(26-28)

In your initial submission, you stated the merchandise will be sold in the following sizes: Extra Small, Small, Medium, Large, 1X, 2X and 3X. .

The process in China is as follows:


The process in Macau is as follows:


The subject garment is described as “boiled wool fabric”, which you described as a fabric that has a boiled effect which is created by washing the panels in hot water, with the result of “shrunk” fabric, that is, the stitches are closer together and the fabric has less stretch-ability.

The subject article also has a stitch count of more than nine stitches per two centimeters measured in the direction in which the stitches were formed. The subject boiled wool jacket is made of the following component parts:

-two front plackets that measure approximately 36 inches in length; -two front panels, one back panel and two sleeves; -two double face folding cuffs which measure approximately 12.5 inches; -two pockets which measure 9.5 inches in length and 8 inches in width; -three components which comprise the hood.

ISSUE: What is the classification and country of origin of the subject coat?


Section 334 of the Uruguay Round Agreements Act (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published September 5, 1995, in the Federal Register, implements Section 334 (60 Fed. Reg. 46188). Section 334 of the URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000, and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, the country of origin of a textile or apparel product shall be determined by sequential application of the general rules set forth in paragraphs (c)(1) through (5) of Section 102.21.

Paragraph (c)(1) states:

The country of origin of a textile or apparel product is the single country, territory, or insular possession in which the good was wholly obtained or produced.

You stated that the subject coat is made of wool fabric originating in China and cut and sewn in Macau. We do not find the coat to be “wholly obtained or produced” as provided in Section 102.21(c)(1) since it is produced in two countries. Therefore, we must consider paragraph (c)(2), which states:

Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or insular possession in which each foreign material incorporated in that good underwent an applicable change in tariff classification and/or met any other requirement, specified for the good in paragraph (e) of this section.

Paragraph (e) states: "The following rules will apply for purposes of determining the country of origin of a textile or apparel product under paragraph (c)(2) of this section."

We have determined that the subject coat is classifiable in subheading 6102.10.0000, HTSUSA, which provides for “Women’s or girls’ overcoats, carcoats, capes, cloaks, anoraks (including ski-jackets), windbreakers and similar articles, knitted or crocheted: other than those of heading 6104: Of wool or fine animal hair.”

Paragraph (e), Section 102.21 in pertinent part, states:

HTSUS Tariff shift and/or other requirements

(1) If the good is not knit to shape and consists of two or more component parts, except for goods of subheading 6117.10 provided for in paragraph (e)(2) of this section, a change to an assembled good of heading 6101 through 6117 from unassembled components, provided that the change is the result of the good being wholly assembled in a single country, territory or insular possession.

In order to ascertain the applicability of section 102.21 (c)(2), we must resolve the issue of whether the subject coat is "knit to shape" as provided by the tariff shift rule of paragraph (e). The term "knit to shape" is defined in section 102.21 (b)(3) as:

Any good of which 50 percent or more of the exterior surface area is formed by major parts [emphasis added] that have been knitted or crocheted directly to the shape used in the good, with no consideration being given to patch pockets, appliques, or the like. Minor cutting, trimming or sewing of those major parts will not affect the determination of whether the good is "knit to shape. See 19 C.F.R. 102.21 (b)(3).

The term “major parts” is defined as “integral components of a good but does not include collars, cuffs, waistbands, plackets, pockets, linings, paddings, trim, accessories, or similar parts.” See Section 102.21(b)(4), Customs Regulations.

You stated that the pieces are knitted, dyed and washed in China, and sent to Macau where they are cut and sewn. Upon review of the sample coat and its eleven components, it is our opinion that the subject coat is not knit to shape, but cut and sewn to form a completed coat. Thus, we do not find the subject coat to be “knit to shape” as provided by section 102.21(b)(3).

Therefore, CBP, relying on 102.21(c)(2), concludes that the conferred country of origin is Macau. Macau is the single country in which the foreign material formed in China and incorporated into the good underwent a change in tariff classification and met the requirements of paragraph (e). The subject wool coat is not a “knit to shape” garment and consists of two or more components. The garment, at the time of importation into the United States, is an assembled good of heading 6102, HTSUS, as the result of the assembly of unassembled components, and was wholly assembled in a single country, Macau.


The subject women’s long wool coat is classifiable in subheading 6102.10.0000, HTSUSA, which provides for “Women’s or girls’ overcoats, carcoats, capes, cloaks, anoraks (including ski-jackets), windbreakers and similar articles, knitted or crocheted: other than those of heading 6104: Of wool or fine animal hair.” The applicable visa category number is 435 and the duty rate is 57.1 cents/kilogram plus 16.8 percent ad valorem. The country of origin is Macau.

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 Textile Status Report for Absolute Quotas, previously available on the Customs Electronic Bulletin Board (CEBB) which can be found on the CBP website at www.cbp.gov.

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 CBP office prior to importation of this merchandise to determine the current status of any import restraints or requirements.

The holding set forth above applies only to the specific factual situation and merchandise identified in the ruling request. This position is clearly set forth in section 19 C.F.R. 177.9(b)(1). This section states that a ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). Should it be subsequently determined that the information furnished is not complete and does not comply with 19 C.F.R. 177.9(b)(1), the ruling will be subject to modification or revocation. In the event there is a change in the facts previously furnished, this may affect the determination of country of origin. Accordingly, if there is any change in the facts submitted to CBP, it is recommended that a new ruling request be submitted in accordance with 19 C.F.R. 177.2.

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.


Myles B. Harmon, Director
Commercial Rulings Division

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