CBP Issues Revised ICP on Classification of Children's Apparel
U.S. Customs and Border Protection has issued a revised version of its informed compliance publication entitled, What Every Member of the Trade Community Should Know About: Classification of Children's Apparel.
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The publication was prepared by the National Commodity Specialist Division of Regulations and Rulings and provides guidance regarding the classification of children's apparel. The ICP was first issued in 1999. It was later revised in May 2005, reviewed with no changes in June 2006, and has since been revised in January 2008.
ICP Contains Information on HTS Headings, Sets, Sizes, Garment Use, Etc.
According to the table of contents, the revised ICP contains information on the following: Introduction, Babies' Wear Headings 6111 and 6209, Babies' Sets and Retail Sets, Sizes, Styling Features, Garment Coverage, Two-Piece Playsuits, Garment Use, Invoicing Requirements, Marking Requirements, Glossary of Children's Wear Terms, and Additional Information.
Highlights of Revisions to ICP on Children's Apparel
Based on a comparison of the June 2006 version of this ICP and the revised January 2008 version, the following changes were noted (partial list):
removal of "Quotas and Textile Categories" section; and
addition of information on, and change for, certain retail sets. The revised ICP renames the section formally entitled, "Babies' Sets" to "Babies' Sets and Retail Sets" and accordingly provides additional information on retail sets.
CBP sources state the revised section also reflects a relatively recent (since 2006) change in CBP's views on the classification of certain imported babies sets, for example, a woven cotton shirt and a woven cotton pant intended to be worn together, that is also imported with the accessory of a pair of knit cotton socks.
In this example, these three items are now considered to be a General Rules of Interpretation (GRI) 3(b) retail set, and will be classified under HTS 6209.20.5035 (other babies sets) even though they do not qualify for classification under HTS 6209.20.5035 (other babies sets) under Chapter 62 Additional U.S. Note 1. (See HQ 968248.)
ICP Provided for Informational Purposes Only
CBP states that the information provided in this publication is for general information purposes only. CBP cautions that because many complicated factors can be involved in customs issues, an importer may wish to obtain a ruling under CBP Regulations, 19 CFR Part 177, or obtain advice from an expert (such as a licensed Customs Broker, attorney or consultant) who specializes in customs matters.
(See ITT's Online Archives or 06/12/06 news, 06061220, for BP summary of CBP's June 2006 ICP on children's apparel, which was reviewed but not changed from its previous edition.
See ITT's Online Archives or 05/10/05 news, 05051015, for BP summary of CBP's May 2005 ICP on children's apparel which was revised from its previous edition.
See ITT's Online Archives or 02/03/00 news, 00020275, for BP summary of CBP's original ICP on children's apparel.)
ICP on children's apparel (revised January 2008) available at http://www.cbp.gov/linkhandler/cgov/toolbox/legal/informed_compliance_pubs/icp036.ctt/icp036.pdf
HQ 968248 (dated 08/31/06) available at http://rulings.cbp.gov/index.asp?ru=968248&qu=968248&vw=detail