Clothing
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 6109100027 | 34.0% | CN | US | Official Doc |
| 6109100004 | 34.0% | CN | US | Official Doc |
| 6217109510 | 32.1% | CN | US | Official Doc |
| 6217108500 | 24.6% | CN | US | Official Doc |
| 7117196000 | 17.5% | CN | US | Official Doc |
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AI Analysis
π Clothing (Apparel & Garments)
π HS Code Reference & Clearance Guide | 2026 Tax Regime Breakdown | Professional Import Strategy
π One: Product Definition & Classification: Do You Really Know "Clothing"?
"Clothing" is a broad term covering a vast array of wearable articles. In international trade, classification depends on material, manufacturing method (knitted vs. woven), and function (garment vs. accessory). Misclassification can lead to significant tariff discrepancies.
Key Distinctions:
- Knitted/Crocheted (61xx): Made by looping yarn (e.g., T-shirts, jerseys).
- Woven (62xx): Made by interlacing threads (e.g., dress shirts, jackets).
- Accessories/Ornaments (6217, 7117): Items like bows, fake jewelry, or costume pieces that accompany clothing but aren't garments themselves.
β οΈ Critical Classification Triggers:
- Material: Cotton (6109.10) vs. Other Textiles (6217).
- Form: Worn directly (Garment) vs. Worn for decoration/accessory.
- Origin: Products from China to the US face specific "Section 301" and "Section 122" surcharges.
π¦ Two: HS Code Classification Details (2026 Authoritative Match)
Based on the provided data, here is the exact classification for the specific "Clothing" variations analyzed:
| HS Code | Product Description & Logic | Tax Detail Breakdown | Total Duty |
|---|---|---|---|
| 6109.10.00.27 | Knitted T-Shirts/Vests β’ Logic: Falls under the "Knitted/Crocheted" category. β’ Status: No material or form conflict found. |
Base: 16.5% Section 301 (Added): 7.5% Section 122: 10% |
34.0% |
| 6109.10.00.04 | Finished Consumer Garments β’ Logic: Fits the "Finished Consumer Goods" profile (T-shirts, vests). β’ Status: Consistent with end-use attributes. |
Base: 16.5% Section 301 (Added): 7.5% Section 122: 10% |
34.0% |
| 6217.10.95.10 | Clothing Accessories (General) β’ Logic: Classified as "Clothing Ornaments/Accessories". β’ Status: Fits the "Catch-all" (Residual) category principle. |
Base: 14.6% Section 301 (Added): 7.5% Section 122: 10% |
32.1% |
| 6217.10.85.00 | Ready-to-Wear Accessories β’ Logic: Matches "Garment Attachments" (e.g., collars, cuffs). β’ Status: No additional Section 301 surcharge applied. |
Base: 14.6% Section 301 (Added): 0.0% Section 122: 10% |
24.6% |
| 7117.19.60.00 | Toy Jewelry / Costume Ornaments β’ Logic: Derived from "Toy Jewelry" usage inference. β’ Status: Fits the "Other" category residual match (non-precious metal). |
Base: 0.0% Section 301 (Added): 7.5% Section 122: 10% |
17.5% |
π Deep Dive on the Surcharges:
- Base Tariff: Standard Most-Favored-Nation (MFN) rate based on the specific textile type.
- Section 301 (Added): Often referred to as the "301 Surcharge" (typically 7.5% or 25%). Notice how 6217.10.85.00 has 0% here, meaning it is exempt from this specific addition.
- Section 122 (122 Clause): A 10% surcharge applied to specific Chinese-origin goods (often under the "Uyghur Forced Labor Prevention Act" or specific trade remedies). Note: All items in this list bear this 10% tax.
π° Three: Detailed Tax Breakdown & Policy Explanation
β Target Market: United States (US)
β Origin: China (CN)
β Policy Context: 2025-2026 Trade War Adjustments
π― Item 1 & 2: Knitted T-Shirts & Finished Garments (6109.10.00.27 / 6109.10.00.04)
| Component | Rate | Legal Basis |
|---|---|---|
| Base Tariff | 16.5% | US HTS Section 61 (Knitted/Crocheted) |
| Section 301 Surcharge | +7.5% | "China Specific" Add-on (List 3/4) |
| Section 122 Clause | +10.0% | Specific Trade Remedy / Forced Labor Related |
| TOTAL | 34.0% | High Risk / High Cost |
π Explanation:
These are standard apparel items (T-shirts, vests). The high tax (34%) is driven by the combination of the base rate and the aggressive 10% Section 122 levy, which is currently active for many Chinese textiles. The 7.5% Section 301 adds further pressure. There is NO de minimis exemption for these goods.
π― Item 3 & 4: Clothing Accessories (6217.10.95.10 / 6217.10.85.00)
| Component | Rate (General Accessory) | Rate (Garment Attachment) |
|---|---|---|
| Base Tariff | 14.6% | 14.6% |
| Section 301 Surcharge | +7.5% | 0.0% (Exempt!) |
| Section 122 Clause | +10.0% | +10.0% |
| TOTAL | 32.1% | 24.6% |
π Explanation:
- General Accessories (e.g., generic costume pieces) pay the full 32.1%.
- Garment Attachments (e.g., specific collars, trims) are cleverly classified to avoid the 7.5% Section 301 surcharge, saving 7.5% in total costs. This is a critical optimization point for importers.
π― Item 5: Costume Jewelry / Toy Ornaments (7117.19.60.00)
| Component | Rate | Legal Basis |
|---|---|---|
| Base Tariff | 0.0% | Non-precious metal / Toy category |
| Section 301 Surcharge | +7.5% | "China Specific" Add-on |
| Section 122 Clause | +10.0% | Specific Trade Remedy |
| TOTAL | 17.5% | Lowest Risk / Best Option |
π Explanation:
If your "clothing ornament" can be legally defined as "Toy Jewelry" or "Costume Ornament" (not a textile accessory), you benefit from a 0% base tariff. However, you still face the 17.5% total due to the Section 301 and 122 clauses. This is the cheapest entry point for decorative items.
π οΈ Four: Clearance Practical Advice (Strategic Guide)
β 1. Documentation Checklist (Mandatory)
| Document | Requirement | Why It Matters |
|---|---|---|
| Product Description | Must specify "Knitted" vs. "Woven" and "Garment" vs. "Accessory". | Determines 61xx vs. 62xx. |
| Material Composition | % Cotton, % Polyester, etc. | Critical for 6109.10 (Cotton) vs. others. |
| Functional Photo | Clear images of how the item is worn (e.g., as a necklace vs. a shirt). | Prevents reclassification from 7117 (Toy) to 6217 (Accessory). |
| Declaration of Origin | Explicit statement of "Made in China". | Triggers Section 122 (10%) and Section 301 (7.5%). |
| Bill of Materials | List of all trims/accessories included. | Prevents "splitting" penalties if accessories are declared separately. |
β 2. Classification Strategy (The "Save Money" Hacks)
π₯ Rule of Thumb: "If it's a trim, don't call it an accessory. If it's jewelry, don't call it a garment."
| Scenario | Recommended Code | Cost Benefit |
|---|---|---|
| Standard T-Shirt | 6109.10.00.04 |
Accept 34% (Standard) |
| Garment Collar/Trim | 6217.10.85.00 |
Save 7.5% (Avoids Sec 301) |
| Fake Jewelry/Necklace | 7117.19.60.00 |
Save 16.5% (0% Base Rate) |
| Generic Costume Piece | 6217.10.95.10 |
Pay 32.1% (Catch-all) |
β 3. Special Handling for Section 122 (10% Tax)
- The 10% Clause: This is currently a hard levy on many Chinese textile imports. It is not waived by the de minimis rule for small shipments (under $800) in many strict interpretations.
- Strategy: Ensure your supplier provides a Country of Origin Certificate that clearly separates "Made in China" items from "Made in Vietnam/Mexico" to avoid accidental inclusion in the 10% tax bracket.
π Five: Global Market Comparison (US vs. Others)
| Region | Target HS Code | Base Tax | Surcharges | Total | Status |
|---|---|---|---|---|---|
| πΊπΈ USA | 6109.10.00.04 |
16.5% | 301 (7.5%) + 122 (10%) | 34.0% | β οΈ High Risk |
| πΊπΈ USA | 7117.19.60.00 |
0.0% | 301 (7.5%) + 122 (10%) | 17.5% | β Best Value |
| πͺπΊ EU | 6109.10.00.04 |
~12% | None | ~12% | β Lower Cost |
| π―π΅ Japan | 6109.10.00.04 |
~10% | None | ~10% | β Lower Cost |
π Insight: The US market is unique in applying both the 10% Section 122 and the 7.5% Section 301 simultaneously. Diversifying supply to Vietnam or Bangladesh could bypass the 10% Section 122, though Section 301 might still apply depending on current rules.
π Six: Common Mistakes & Pitfalls (Avoid These!)
β Mistake 1: Calling a "Costume Necklace" a "Garment Accessory" (6217).
π Result: You pay 32.1% instead of 17.5%.
π Fix: Classify under 7117 (Toy Jewelry) if it's plastic/metal costume wear.
β Mistake 2: Calling a "Collar" a "Garment" (6109).
π Result: You pay 34% instead of 24.6%.
π Fix: Prove it is a "Trim/Attachment" (6217.10.85.00) to avoid the 7.5% surcharge.
β Mistake 3: Assuming "Knitted" covers everything.
π Result: Woven items misclassified as Knitted lead to audits and fines.
π Fix: Double-check fabric structure (looped vs. woven).
β Correct Declaration:
"100% Cotton Knitted T-Shirt, for Adult Men, Model XYZ, Made in China. Declared as Finished Garment."
vs.
"Plastic Costume Necklace, Toy Jewelry, Made in China. Declared as 7117 Item."
π― Seven: Conclusion & Action Plan
π― Key Takeaway:
πΉ Garments = 34% (High tax due to 122+301).
πΉ Garment Attachments = 24.6% (Save 7.5% by avoiding Section 301).
πΉ Costume Jewelry = 17.5% (Save 16.5% by using 0% base rate).
π Action Steps:
1. Audit your SKU list: Are any "accessories" actually "garment attachments"?
2. Redefine "Ornaments": Can they be marketed as "Toy Jewelry" (7117) to lower base tax?
3. Pre-File Rulings: Consult a customs broker for a Binding Ruling on complex items like "Clothing Ornaments."
π£ Final Warning:
"In the current 2026 trade environment, a 1% difference in HS Code classification can cost you thousands of dollars in tariffs. Classify precisely, document thoroughly, and optimize your tax bracket!"
β¨ Professional Clearance Starts with the Right Code!
πΌ Your profit margin depends on your HS Code strategy!
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About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.