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NY N012571

June 20, 2007



TARIFF NO.: 6206.10.0040

Ms. Donna L. Shira
Sharretts, Paley, Carter & Blauvelt P. C. 75 Broad Street
New York, NY 10004

RE: The tariff classification of a woman’s upper body garment from China

Dear Ms. Shira:

In your letter dated June 4, 2007, you requested a classification ruling on behalf of Polo Ralph Lauren Corp. Your sample will be returned as requested.

Submitted sample, style #17P16, is a woman’s blouse constructed from both woven and knit fabric. The woven fabric is composed of 100% silk and the knit fabric is composed of 95% cashmere and 5% polyester. The garment is collarless and features a woven front panel embellished with beads and appliqués, a v-neckline, a full front opening secured by seven buttons. The garment also has long knit sleeves and a knit back panel.

The woven component imparts the essential character of the garment; therefore, the garment will be classified based on GRI 3(b), which states that garments will be classified by the component, which gives them their essential character. As such, the garment is classified as a woman’s woven blouse under heading 6206, HTS.

In your letter you suggest a classification of subheading 6211.49.10, HTS. The garment does possess any characteristics to exclude classification from subheading 6206. Style 17P16 is properly classified under heading 6206, HTS.

The applicable subheading for the style 17P16 will be 6206.10.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for women’s or girls’ blouses, shirts and shirt-blouses: of silk or silk waste: other: containing 70 percent or more by weight of silk or silk waste. The duty rate will be 6.9 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

Style 17P16 falls within textile category 741. With the exception of certain products of China, quota/visa requirements are no longer applicable for merchandise which is the product of World Trade Organization (WTO) member countries. The textile category number above applies to merchandise produced in non-WTO member-countries. Quota and visa requirements are the result of international agreements that are subject to frequent renegotiations and changes. To obtain the most current information on quota and visa requirements applicable to this merchandise, we suggest you check, close to the time of shipment, the “Textile Status Report for Absolute Quotas” which is available on our web site at www.cbp.gov. For current information regarding possible textile safeguard actions on goods from China and related issues, we refer you to the web site of the Office of Textiles and Apparel of the Department of Commerce at otexa.ita.doc.gov.

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 Brenda Wade at 646-733-3051.


Robert B. Swierupski

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