At times, determining the tariff classification of an outerwear garment can be an especially daunting task for me. There are so many new fabrics on the market these days and fashion trends are, as one expects, always changing — and when these two factors are taken together, it can have a profound effect on the resulting characteristics and distinguishing features of various outerwear garments.
Complicating matters further, Clients/Designers provide details, on HTS Code Requests, that are not applicable to determining the garment’s HTS code for customs purposes. Often when I take the designer information and compare it to the CBP requirements, I sometimes feel like I’m putting together a 500-piece puzzle with only 412 pieces in the box. It’s a challenge! But hey, if you’re like me – you just love a challenge, right?
When first embarking on my outerwear classification challenge, it seemed logical to read CROSS ruling to define CBP’s methodology. But sadly, that approach just ended up leaving me cross-eyed, with brain-fog.
Different CROSS rulings often seem to describe the same garment, but then curiously wind up assigning different tariffs to them. For example, a CROSS ruling of a jacket with a so-called tightening at the bottom says the jacket is “more sweater like” and is classified under 6110; yet another CROSS ruling says the exact same type of jacket is classified under 6102.
When I look at the published CBP outerwear requirements and CROSS Rulings, I often scratch my head and sigh out of frustration, because so many jacket requirements are subject to interpretation and as we all know, CBP’s interpretation is the only one that matters. Despite the CROSS Rulings I’ve read and/or submitted to CBP on Outerwear, I am still truly perplexed about what CBP considers enough “tightening” at the bottom of the jacket to provide sufficient protection from the elements. Are we talking Northern states’ elements or Southern states’ elements? Y’all know - there’s a huge difference between the two!
Thus, I set out to create a detailed page conclusively Defining Anoraks, Parkas & Coats, which contains a corresponding link to the relevant CROSS ruling analysis. Additionally, in order to more effectively gather all the required information from Clients/Designers for classification purposes, I also created a Garment Classification Check Sheet. Hopefully, these handy resources will also be of some assistance to you in figuring out the evolving and never-ending adventure that is textile and apparel classification!
And remember – if in doubt – submit a Cross Ruling Request to CBP.
Note: CBP has not issued recent rulings on outerwear garments, because of CIT Court Case - Item House, Inc. v. US, CIT No. 14-00095, has not yet been determined. Final determination could affect outerwear garment classification.
Lynne McGowan - Senior Textile & Apparel Specialist
GHY International | Geo. H. Young & Co. Ltd. | GHY USA, Inc.
1 (888) 825-0002 | email@example.com