Ladies' overalls; Heading 6204
Active· CBP ruling HQ 089037· Issued 1991-07-11
Ruling text
HQ 089037
July 11,1991
CLA-2 CO:R:C:T 089037 jlj
CATEGORY: Classification
TARIFF NO.: 6204.62.2010
Mr. Tommy Lai, Second Secretary
Hong Kong Economic & Trade Affairs
British Embassy
1233 20th Street, N. W., Suite 504
Washington, D. C. 20036
RE: Ladies' overalls; Heading 6204
Dear Mr. Lai:
In your letters of March 5 and March 15, 1991, you asked
that we reconsider the tariff classification and quota category
assigned to ladies' 100 percent woven cotton overalls imported
from Hong Kong (your case no. HK 53/91). You submitted a sample
pair along with your letters.
FACTS:
The instant ladies' overalls, Style No. 635682P, were
imported on Entry No. 231-4720526-6 at the port of Los Angeles
for the account of Fashion Resources Inc. Customs requested a
visa for category 359.
The instant garment is a shortleg ladies' 100 percent woven
cotton overall with a front bib rise of 9 inches. You believe
that the visa issued for category 359(1), a category designated
for cotton overalls, coveralls and jumpsuits, is correct. You
ask that the Department of Commerce adjust the 1990 import
statistics from Hong Kong to show a decrease of 790 kilograms in
category 359 and a commensurate increase in category 359(1).
ISSUE:
Is the instant garment a bib and brace overall for tariff
and quota purposes?
LAW AND ANALYSIS:
Customs Headquarters Ruling Letter (HRL) 088677 of March 15,
1991, and HRL 088526 of March 19, 1991, addressed the issue of
what constitutes bib and brace overalls within the meaning of
Explanatory Note 6103 (E). These letters held that trouser like
garments with a full front bib and over the shoulder straps which
are commonly and commercially known as bib and brace overalls
should be classified as such.
Upon examination of Style No 635682P, it is apparent that
this garment meets the criteria for bib and brace overalls.
HOLDING:
Following the rationale above, the instant garment is
classified under subheading 6204.62.2010 of the HTSUSA, in the
provision for women's or girls' skirts, trousers, bib and brace
overalls, breeches and shorts: of cotton: other, dutiable at the
rate of 9.5 percent ad valorem. Textile category category 359(1)
pertains to importations from Hong Kong under this tariff number.
Your sample is being returned to you as requested. A copy
of this letter is being sent to the Department of Commerce for
appropriate action.
Sincerely,
John Durant, Director
Commercial Rulings Division
Source: rulings.cbp.gov — ruling 089037, retrieved 2026-10-12T05:21:30Z, republished verbatim. This digest is informational; only CBP issues binding rulings.