Classification of men's overalls and shortalls; Heading 6203, HTSUSA
Active· CBP ruling HQ 088808· Issued 1991-04-01
Ruling text
HQ 088808
April 1, 1991
CLA-2 CO:R:C:T 088808 CMR
CATEGORY: Classification
TARIFF NO.: 6203.42.2010
Ms. Cecilia Castellanos
Withrow, Zerwekh & Co.
1241 Watson Center Road
Carson, CA. 90745
RE: Classification of men's overalls and shortalls; Heading 6203,
HTSUSA
Dear Ms. Castellanos:
This ruling is in response to your letter of January 29,
1991, on behalf of Irving B. Reder & Co., requesting the
classification of men's overalls, style 2999, and men's
shortalls, style 1998. The garments will be made in Taiwan,
China and Hong Kong and will be imported through the port of Los
Angeles. Sample garments were received with your submission and
will be returned, as requested, under separate cover.
FACTS:
Two samples were submitted: men's overalls, style 2999, and
men's shortalls, style 1998. Both garments are made of 100
percent woven cotton fabric. The garments are similar in basic
design with each having a front bib that is squared off at the
top and featuring a large horizontal pocket.
The overalls, style 2999, have a horizontal pocket of two
separate segments on the front bib. The rear bib tapers to
straps that connect to the front bib by means of metal hooks.
The garment has two diagonal side pockets. At each of the side
pockets there is a separation between the front and rear panels
secured by three vertical buttons. The garment features a pocket
on the lower front right leg, two rear pockets, and a defined
waist, on both the front and rear panels, encircled by belt
loops. The garment also has a fly front with a zipper closure.
The shortalls, style 1998, have a large plain horizontal
pocket on the front bib. The rear bib tapers to straps that
connect to the front bib by means of metal hooks. The garment
has two scoop side pockets. The right side pocket contains a
watch pocket. At each of the side pockets there is a separation
between the front and rear panels secured by two vertical
buttons. The garment has two upper rear pockets and a smaller
pocket below the upper right rear pocket. The front panel has a
defined waist, the rear panel does not. The waist area is
encircled by belt loops. The garment has a fly front with a
zipper closure.
ISSUE:
Are the men's overalls, style 2999, and men's shortalls,
style 1998, classifiable as men's bib and brace overalls of
heading 6203, HTSUSA?
LAW AND ANALYSIS:
Classification of goods under the HTSUSA is governed by the
General Rules of Interpretation (GRIs). GRI 1 provides that
"classification shall be determined according to the terms of the
headings and any relative section or chapter notes, provided such
headings or notes do not otherwise require, according to [the
remaining GRIs taken in order]."
Heading 6203, HTSUSA, provides for, among other things,
men's and boys' bib and brace overalls. The Explanatory Notes,
which are the official interpretation of the HTSUSA at the
international level state, at page 833, that the term "bib and
brace overalls" means garments of the type illustrated, on page
834, and similar garments which do not cover the knee.
In HRL 088677 of March 15, 1991, Customs addressed the
significance of the illustrations in the Explanatory Notes and
the meaning of the term "bib and brace overalls" for tariff
purposes. In that ruling, Customs determined that "absent a
clear and reasonable description in the Explanatory Notes, which
we do not find in this instance, Customs will apply the common
and commercial meaning to [the term bib and brace overalls].
Therefore, if a trousers-like garment has a full front bib, over
the shoulder straps, and is commonly and commercially known as
overalls, that garment is classifiable under the appropriate
subheadings for bib and brace overalls.
The men's overalls at issue herein meet the above-stated
criteria. The men's shortalls also meet the criteria with the
exception that they do not cover the knee. However, the
Explanatory Notes indicate that such garments are included within
the meaning of the term "bib and brace overalls".
-3-
HOLDING:
The men's overalls, style 2999, and men's shortalls, style
1998, at issue here, are classifiable in the subheading for men's
cotton bib and brace overalls in subheading 6203.42.2010, HTSUSA,
textile category 359, dutiable at 11 percent ad valorem.
The designated textile and apparel category may be
subdivided into parts. If so, the visa and quota requirements
applicable to the subject merchandise may be affected. Since
part categories are the result of international bilateral
agreements which are subject to frequent renegotiations and
changes, to obtain the most current information available, we
suggest you check, close to the time of shipment, the Status
Report On Current Import Quotas (Restraint Levels), an internal
issuance of the U.S. Customs Service which is updated weekly and
is available for inspection at your local Customs office.
Due to the changeable nature of the statistical annotation
(the ninth and tenth digits of the classification) and the
restraint (quota/visa) categories, you should contact your local
Customs office prior to importation of this merchandise to
determine the current status of any import restraints or
requirements.
Sincerely,
John Durant, Director
Commercial Rulings Division
Source: rulings.cbp.gov — ruling 088808, retrieved 2026-10-12T05:21:16Z, republished verbatim. This digest is informational; only CBP issues binding rulings.