CBP Revises ICP on Hats and Other Headgear
U.S. Customs and Border Protection has posted a June 2008 revised version of its Informed Compliance Publication "Classification of Hats and Other Headgear (under HTSUS Heading 6505)" as part of its series "What Every Member of the Trade Community Should Know About."
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This publication was prepared by the National Commodity Specialist Division of Regulations and Rulings in order to provide guidance to the trade community. It was first published in March 1999, and was then revised in January 2004 and May 2005. It was reviewed with no changes in June 2006, and has now been revised in June 2008.
ICP Revised for "Baseball-Style" Caps with Ornamental Braid
According to CBP sources, this ICP is different in only one respect from its prior (2006) version. It has been revised to reflect CBP's 2005 final interpretive rule on man-made fiber (MMF) baseball style caps with ornamental braid.
(Under the final interpretive rule, ornamental braid on a baseball-style cap, located between peak and crown in a width of 1/8 of an inch or greater, will render the cap classifiable in the HTS as "wholly or in part of braid." Conversely, such braid in a width of less than 1/8 of an inch will result in a cap being classifiable in the HTS as "not in part of braid.")
Classification of Hats and Other Headgear under HTS 6505
HTS 6505 includes two six-digit HTS subheadings: hair-nets (HTS 6505.10) and other headgear (HTS 6505.90), the later of which is divided by component material and construction (knit , not knit, etc.) into eight-digit subheadings:
of cotton, flax, or both (HTS 6505.90.15 through 6505.90.25)
of wool (HTS 6505.90.30 through 6505.90.40)
of MMF (HTS 6505.90.50 through 6505.90.80), and
of other (HTS 6505.90.90).
CBP notes that importers and brokers commonly enter HTS 6505 products under incorrect eight-digit subheadings based on the wrong material or wrong construction.
CBP also notes, among other things, that:
- Visors and other headgear which do not cover the crown of the head must be accurately described as there are separate statistical breakouts for this type of merchandise.
- Statistical breakouts for babies' hats and headgear are provided and such items must be sized 0 to 24 months (toddler sizes do not fall under these numbers).
- Woven cotton hats are often incorrectly classified under the HTS 6505.90.2590 provision for woven flax headgear (cat 859). However, woven cotton hats are properly classified as other cotton woven headgear under HTS 6505.90.2060 (cat 359) which pertains to both cotton woven certified hand-loomed and folklore products and woven headgear of cotton (other than for babies).
- Many items have been determined to be hats and headgear of HTS 6505 rather than festive articles of HTS 9505.
(See ITT's Online Archives or 06/12/06 news, 06061220, for BP summary of 2006 ICP. See ITT's Online Archives or 04/04/05 news, 05040430, for BP summary of CBP's final interpretive rule on baseball-style caps with ornamental braids.)
CBP's 2008 ICP available at http://www.cbp.gov/linkhandler/cgov/trade/legal/informed_compliance_pubs/icp034.ctt/icp034.pdf.