RE: The tariff classification of women’s ski jackets, pants, and overalls from China

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363543 August 21, 2026 CLA-2-62:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 6210.30.5020; 6210.50.0531; 6210.50.0540 Ms. Mikayla Balfour Nexarina 111 Courtenay Terrace Sherwood Park T8A 5S6 Canada RE: The tariff classification of women’s ski jackets, pants, and overalls from China Dear Ms. Balfour: In your letter dated July 22, 2026, you requested a tariff classification ruling. Your samples will be returned as requested. All three garments are designed for skiing and snowboarding activities. The shells are constructed from a three-layer laminated fabric consisting of an outer layer of 100% polyester woven fabric treated with durable water repellent (DWR), a middle layer of a 70% polyurethane and 30% polypropylene laminate membrane, and an inner layer of 100% polyester woven fabric. Each garment is lined with woven man-made fabric and insulated with 60g/m2 PrimaLoft® polyester. The submitted sample, Style J-001 “Indy Jacket,” is a women’s hip-length jacket. The jacket has an adjustable hood with two tightening drawcords. The jacket features an asymmetric full front opening with a zippered closure that extends to the base of the hood, an inner storm flap, inner drawcords at the waist and bottom hem, long sleeves with hook-and-loop tabs, and knit fabric inner storm cuffs with thumbholes. The jacket has multiple pockets: one large zippered chest pocket and one zippered waist pocket (both with hook-and-loop flaps), two zippered upper-arm pockets with hook-and loop flaps, and two zippered sleeve pockets. The submitted sample, Style P-001 “Avani Pant,” is a women’s ankle-length pant. The pant has a fly front opening with a zippered closure, a waistband with a double-snap closure and adjustable hook-and-loop tabs, a nd a drawcord threaded under the belt loops for cinching. The garment features two front slant pockets with zippered closures at the waist, two horizontal pockets with zippered closures at the thigh area of the front panels, two back pockets with zippered and flap closures, scuff guards on the lower portion of each leg, partial lower side openings with zippered closures for boot access, and hemmed leg openings with hidden elasticized leg sleeves.
The submitted sample, Style P-002 “Everette Bib,” is a women’s bib and brace overall. The garment has elasticized suspenders that cross in the back, a partially elasticized rear waist, and a zippered opening on each side extending from the underarm to the knee. The bib front includes a pocket with zippered and hook-and-loop flap closures and a smaller zippered pocket underneath. There are also two front slant pockets with zippered closures at the waist and two back pockets with zippered and hook-and-loop flap closures. Additionally, the garment features scuff guards on the lower portion of each leg, partial lower side openings with zippered closures for boot access, and hemmed leg openings with hidden elasticized leg sleeves. Regarding the claim of recreational performance outerwear, per Chapter 62, Additional U.S. Note 3, Harmonized Tariff Schedule of the United States (HTSUS), the term “recreational performance outerwear” means trousers (including, but not limited to, ski or snowboard pants, and ski or snowboard pants intended for sale as parts of ski-suits), coveralls, bib and brace overalls, jackets (including, but not limited to, full zip jackets, ski jackets and ski jackets intended for sale as parts of ski-suits), windbreakers and similar articles (including padded, sleeveless jackets), of fabrics of cotton, wool, hemp, bamboo, silk or man-made fibers, or a combination of such fibers; that are either water resistant within the meaning of Chapter 62, Additional U.S. note 2 or treated with plastics, or both; with critically sealed seams, and with five or more of the following features: (i) insulated for cold weather protection; (ii) pockets, at least one of which has a zippered, hook and loop, or other type of closure; (iii) elastic, drawcord or other means of tightening around the waist or leg hems, including hidden leg sleeves with a means of tightening at the ankle for trousers and tightening around the waist or bottom hem for jackets; (iv) venting, not including grommet(s); (iv) articulated elbows or knees; (v) reinforcement in one of the following areas: the elbows, shoulders, seat, knees, ankles or cuffs; (vi) weatherproof closure at the waist or front; (vii) multi-adjustable hood or adjustable collar; (ix) adjustable powder skirt, inner protective skirt or adjustable inner protective cuff at sleeve hem; (x) construction at the arm gusset that utilizes fabric, design or patterning to allow radial arm movement; or (xi) odor control technology We have reviewed the garment samples and determined that all three styles meet the definition of recreational performance outerwear (RPO). Each garment is of an eligible RPO garment type, constructed from eligible man-made fibers, and treated with plastic, and each features critically sealed seams. Style J-001 has the following RPO features: zippered pockets, waist and hem tightening, underarm mesh vents, an inner storm flap, a multi-adjustable hood, and a powder skirt. Style P-001 has the following RPO features: zippered pockets, a drawcord tightening at the waist, inner thigh mesh vents, articulated knees, and reinforcement with scuff guards above the ankles. Style P-002 has the following RPO features: zippered pockets, an elasticized rear waist and elasticized leg cuffs, inner-thigh mesh vents, articulated knees, and reinforcement with scuff guards above the ankles. You propose classification of all three styles under heading 6210, HTSUS, which provides for garments made up of fabrics of headings 5602, 5603, 5903, 5906 or 5907. We agree. Consistent with Chapter 59, Note 3, HTSUS, textile fabrics laminated with plastics where the layers are bonded together by any process are classified under heading 5903, whether or not the sheets or film of plastics are visible to the naked eye in the cross-section.
Additionally, you propose classification of all three styles under their respective subheadings for recreational performance outerwear. We agree because the three garments meet the requirements for RPO classification. The applicable subheading for Style J-001 will be 6210.30.5020, HTSUS, which provides for “Garments, made up of fabrics of heading 5602, 5603, 5903, 5906, or 5907: Other garments of the type described in heading 6202: Of man-made fibers: other: Anoraks (including ski-jackets), windbreakers and similar articles: Recreational performance outerwear.” The general rate of duty will be 7.1% ad valorem. The applicable subheading for Style P-001 will be 6210.50.0531, HTSUS, which provides for “Garments, made up of fabrics of heading 5602, 5603, 5903, 5906 or 5907: Other women’s or girls’ garments: Recreational performance outerwear: of man-made fibers: Trousers, breeches and shorts: Ski/snowboard pants.” The general rate of duty will be 7.1% ad valorem. The applicable subheading for Style P-002 will be 6210.50.0540, HTSUS, which provides for “Garments, made up of fabrics of heading 5602, 5603, 5903, 5906 or 5907: Other women’s or girls’ garments: Recreational performance outerwear: of man-made fibers: Overalls and coveralls.” The general rate of duty will be 7.1% ad valorem. 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 Rosemarie Hayward at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division