The tariff classification of women’s upper body garments from Vietnam

N362151
June 29, 2026
CLA-2-61:OT:RR:NC:N3:356
CATEGORY: Classification
TARIFF NO.: 6109.90.1090; 6110.30.3059
Mr. SeungHyun Jung Theory LLC 165 Polito Avenue Lyndhurst, NJ 07071 RE: The tariff classification of women’s upper body garments from Vietnam Dear Mr. Jung: In your letter dated June 8, 2026, you requested a tariff classification ruling. Your samples will be returned as you requested. Style 04276F043A “W’s HEATTECH crew neck T-shirt” is a women’s cut and sewn upper body garment constructed from 33 percent polyester, 31 percent acrylic, 21 percent rayon, and 15 percent spandex knit fabric. The outer surface of the garment’s fabric measures more than nine stitches per two centimeters in the direction the stitches were formed. The snug-fitting garment extends from the shoulders to below the waist and features a crew neckline; long, hemmed sleeves; and a straight, hemmed bottom. Style 04275F059Q “W’s CPJ HEATTECH EXW cashmere blend crew neck T-shirt” is a women’s cut and sewn upper body garment constructed from 57 acrylic, 28 percent rayon, 9 percent cashmere, and 6 percent spandex, lightweight jersey knit fabric. The snug-fitting garment extends from the shoulders to below the waist and features a crew neckline; long, hemmed sleeves; and a straight, hemmed bottom. Style 04275F060R “W’s CPJ HEATTECH EXW cashmere blend turtleneck T-shirt” is a women’s cut and sewn upper body garment that is similar to a T-shirt. It is constructed from 57 acrylic, 28 percent rayon, 9 percent cashmere, and 6 percent spandex jersey knit fabric. The outer surface of the garment’s fabric measures more than nine stitches per two centimeters in the direction the stitches were formed. The snug-fitting garment extends from the neck to below the waist and features a fitted high neckline; long, hemmed sleeves; and a straight, hemmed bottom. Style 04275F026R “W’s HEATTECH Ultra Warm crew neck T-shirt” is a women’s cut and sewn upper body garment constructed from 35 percent acrylic, 34 percent polyester, 23 percent rayon, and 8 percent spandex knit fabric that is brushed on its inner surface. The outer surface of the garment’s fabric measures more than nine stitches per two centimeters in the direction the stitches were formed. The snug-fitting

garment extends from the shoulders to below the waist and features a crew neckline; long, hemmed sleeves; and a straight, hemmed bottom. The applicable subheading from Styles 04276F043A, 04275F060R, and 04275F026R will be 6110.30.3059, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Sweaters, pullovers, sweatshirts, waistcoats (vests), and similar articles, knitted or crocheted: Of man-made fibers: Other: Other: Other: Other: Other: Women’s or girls’: Other. The general rate of duty will be 32 percent ad valorem. The applicable subheading for Style 04275F059Q will ne 6109.90.1090, HTSUS, which provides for: T-shirts, singlets, tank tops and similar garments, knitted or crocheted: Of other textile materials: Of man-made fibers: Women’s or girls’: Other. The general rate of duty will be 32 percent ad valorem. The retail packaging of the subject garments is not properly marked with the garments’ country of origin. Specifically, the front of each sealed retail package contains the words “Japan Technology” in lettering ranging from approximately 1/16 inch to 1/8 inch in height, while on the reverse side of each package, the country of origin of the garment is printed in smaller font. 19 Code of Federal Regulations (CFR) 134.46 states, in relevant part: In any case in which… the name of any foreign country or locality other than the country or locality in which the article was manufactured or produced appear on an imported article or its container, and those… names may mislead or deceive the ultimate purchaser as to the actual country of origin of the article, there shall appear legibly and permanently in close proximity to such… name, and in at least a comparable size, the name of the country of origin preceded by “Made in,” “Product of,” or other words of similar meaning. In order to satisfy the “close proximity” requirement of 19 CFR 134.46, the country of origin must generally appear on the same side or surface on which the name or locality other than the actual country of origin appears. Further, as indicated above, the country of origin font on each retail package must be of at least comparable size to the “Japan Technology” lettering. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR

177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Maryalice Nowak at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division