RE: The tariff classification, country of origin, and status under the Dominican Republic-Central America-United States Free Trade Agreement (DR-CAFTA)

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 N363781 August 21, 2026 OT:RR:NC:N1:358 CATEGORY: Origin TARIFF NO.: 6505.00.6090 Andy Lee D and A Customs Services Inc 152 W Walnut Street, Suite 260 Gardena, CA 90248 RE: The tariff classification, country of origin, and status under the Dominican Republic-Central America-United States Free Trade Agreement (DR-CAFTA) Dear Mr. Lee: In your letter dated July 28, 2026, you requested a tariff classification, country of origin determination, and eligibility for preferential tariff treatment under the Dominican Republic-Central America-United States Free Trade Agreement (DR-CAFTA) for a baseball-style cap. Samples and supporting documentation were submitted for our review. FACTS: The submitted sample, identified as FLEX baseball-style cap, is composed of six panels. The sewn-in label indicates the cap is constructed of 74% polyester and 26% cotton woven fabric. The two front panels are constructed of woven fabric, and the rear panels are constructed of polyester mesh fabric. The cap features a fabric-covered button at the apex of the crown, two eyelets on the front panels, and an adjustable two-piece plastic snapback closure at the rear. The submitted sample is marked “Made in Bangladesh.” In subsequent correspondence, you stated that the sample is representative of the merchandise that will be manufactured in the Dominican Republic with respect to their fiber composition, materials, construction, and design. You also stated that the manufacturer, Yupoong, does not currently operate a manufacturing facility in the Dominican Republic; that it is being established and that is expected to be completed in December 2028 with production expected to commence in April 2029. In the Dominican Republic, the fabric will be cut into the component pieces of the cap. The crown panels will be prepared and sewn together, the peak will be constructed and assembled to the crown, and the remaining components, including the sweatband, top button, and adjustable closure, will be attached. The completed cap will undergo final assembly, finishing, steaming, inspection and packing.
According to the submitted bill of materials (BOM), the materials used in the production of the cap will originate in the Dominican Republic, Vietnam, and the Republic of Korea. The non-originating materials include polyester mesh fabric, CVC fabric, sewing thread, tape, buckram, elastic band, a top button, a plastic peak board, and a two-piece plastic snapback closure. Certain labels, stickers, packing materials, and other components will originate in the Dominican Republic. The BOM identifies the plastic snapback closure as classified in heading 6507, Harmonized Tariff Schedule of the United States, (HTSUS). However, based on our examination of the submitted sample and consistent Headquarters Ruling Letter (HQ) 087750, dated November 16 1990, we find that the two-piece plastic snapback closure is properly classified in heading 3926, HTSUS. CLASSIFICATION: Goods that are, prima facie, classifiable under two or more headings are classifiable in accordance with General Rule of Interpretation (GRI) 3, Harmonized Tariff Schedule of the United States (HTSUS). GRI 3(b) states in relevant part that “composite goods consisting of different materials or made up of different components… which cannot be classified by reference to 3(a) shall be classified as if they consisted of the material or component that gives them their essential character…” Here, there is no dispute that the cap is classified in heading 6505, as the materials that make-up the cap are classified within this heading. Rather, the issue is the proper classification at the subheading level. The FLEX baseball-style cap is prima facie, classifiable under two subheadings. Neither the front two panels of woven fabric (6505.00.20, HTSUS) nor the polyester knit mesh (6505.00.60, HTSUS) imparts the essential character of the cap. As a result, GRI 6, which governs classification at the subheading level, applies as well. Based on the provided information, the applicable subheading for the FLEX baseball-style cap will be 6505.00.6090, HTSUS, which provides for “Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed; hair-nets of any material, whether or not lined or trimmed: Other: Other: Of man-made fibers: Knitted or crocheted or made up from knitted or crocheted fabric: Not in part of braid: Other: Other: Other.” The general rate of duty will be 20 cents per kilogram plus 7 percent 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 Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. COUNTRY OF ORIGIN – LAW AND ANALYSIS: Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customs
laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described as Congress’s expression of substantial transformation as it relates to textile and apparel products. Section 102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of origin of a textile or apparel product shall be determined by the sequential application of the general rules set forth in paragraphs (c)(1) through (5) of section 102.21. See 19 CFR 102.21(c). 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.” As the subject merchandise is not wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section 102.21 is inapplicable. Paragraph (c)(2) 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 of the foreign materials 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) in pertinent part states, The following rules shall apply for purposes of determining the country of origin of a textile or apparel product under paragraph (c)(2) of this section: “For any other good, if the good consists of two or more components, a change to goods of subheading 6505.00, other than hair-nets, from any other hair-nets, from any other heading, provided that the change is the result of the good being wholly assembled in a single country, territory, or insular possession.” The term “wholly assembled” is defined in 102.21(b)(6) as follows: The term “wholly assembled” when used with reference to a good means that all components, of which there must be at least two, pre-existed in essentially the same condition as found in the finished good and were combined to form the finished good and were combined to form the finished good in a single country, territory, or insular possession. The subject FLEX baseball-style cap consists of two or more components. The materials used to produce the cap will be sourced from the Dominican Republic, Vietnam, and the Republic of Korea. In the Dominican Republic, the fabrics will be cut into component pieces, the crown panels will be sewn together, the peak will be constructed and attached to the crown, and the remaining components will be incorporated and assembled into the completed cap. Accordingly, pursuant to 19 CFR 102.21(c)(2), the FLEX baseball-style cap meets the tariff shift requirements and therefore, the country of origin is conferred by the Dominican Republic. DR-CAFTA ELIGIBILITY: General Note (GN) 29, HTSUS, sets forth criteria for determining whether a good is originating under the DR-CAFTA. GN 29(b), HTSUS (19 U.S.C. § 1202) states: For the purposes of this note, subject to the provisions of subdivisions (c), (d), (m) and (n) thereof, a good imported into the customs territory of the United States is eligible for treatment as an originating good under the terms of this note if —
(i) the good is a good wholly obtained or produced entirely in the territory of one or more of the parties to the Agreement; (ii) the good was produced entirely in the territory of one or more of the parties to the Agreement, and — (A) each of the non-originating materials used in the production of the good undergoes an applicable change in tariff classification specified in subdivision (n) of this note; or (B) the good otherwise satisfies any applicable regional value content or other requirements specified in subdivision (n) of this note; and the good satisfies all other applicable requirements of this note; or (iii) the good was produced entirely in the territory of one or more of the parties to the Agreement exclusively from originating materials. The FLEX baseball cap will be produced in the Dominican Republic from originating and non-originating materials. The materials sourced from Vietnam and the Republic of Korea are non-originating materials for purposes of DR-CAFTA. Therefore, the non-originating materials must undergo the applicable change in tariff classification specified in GN 29(n) in order to meet the requirements of GN 29(b)(ii)(A). For goods classified in heading 6505, GN 29(n), Chapter 65, rule 2 requires: A change to headings 6504 through 6506 from any other heading, except from headings 6504 through 6507. According to the submitted BOM, the non-originating materials used in the production of the subject cap are classified in headings outside the excluded range of headings 6504 through 6507, with the exception of the plastic snapback closure, which the BOM identifies in heading 6507, HTSUS. As discussed above, although the submitted BOM identifies the two-piece plastic snapback closure in heading 6507, HTSUS, the closure is properly classified in heading 3926, HTSUS, consistent with HQ 087750. Accordingly, the Vietnamese-origin plastic snapback closure undergoes the requisite change from heading 3926 to heading 6505, HTSUS, and satisfies the applicable tariff shift requirement. Based on the facts provided, the FLEX baseball-style cap qualifies for preferential tariff treatment under the DR-CAFTA because it meets the requirements of GN 29(b)(ii)(A), HTSUS. HOLDING: The FLEX baseball-style cap is classified in subheading 6505.00.6090, HTSUS, which provides for “Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed; hair-nets of any material, whether or not lined or trimmed: Other: Other: Of man-made fibers: Knitted or crocheted or made up from knitted or crocheted fabric: Not in part of braid: Other: Other: Other.” The general rate of duty will be 20 cents per kilogram plus 7 percent ad valorem. The country of origin of the FLEX baseball-style cap is the Dominican Republic. Based upon the facts presented, the FLEX cap satisfies the applicable tariff shift requirement of GN 29(n), Chapter 65, rule2, and qualifies as an originating good pursuant to GN 29(b)(ii)(A), HTSUS. Accordingly, the merchandise is eligible for preferential tariff treatment under the DR-CAFTA, provided that all other applicable requirements are met.
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 Katherine Souffront at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division