WEBVTT 00:00:15.250 --> 00:00:16.080 NOWAK, MARYALICE OK. 00:00:16.080 --> 00:00:20.320 Well, hello everyone, and welcome to today's webinar on changes 00:00:20.320 --> 00:00:24.290 to the 2022 harmonized tariff schedule and what they mean 00:00:24.290 --> 00:00:25.070 for Mens apparel. 00:00:26.273 --> 00:00:28.060 NOWAK, MARYALICE My name is Mary Ellen Noah, 00:00:28.060 --> 00:00:31.420 and I am the national import specialist for Mens apparel, 00:00:31.420 --> 00:00:32.810 but with some exceptions. 00:00:32.810 --> 00:00:35.290 For example, I don't handle outerwear. 00:00:35.290 --> 00:00:40.730 I don't handle sleepwear or swimwear or certain types of protective clothing, 00:00:40.730 --> 00:00:46.100 but most other items have Mens apparel do eventually find their way to things. 00:00:46.100 --> 00:00:49.680 Now, First things first, for those of you who might be new 00:00:49.680 --> 00:00:54.700 to Microsoft Teams and I'm pretty new to it myself, so full disclaimer. 00:00:54.700 --> 00:00:55.850 Hopefully this goes on for. 00:00:55.850 --> 00:00:57.530 NOWAK, MARYALICE Gotta get you today. 00:00:58.250 --> 00:01:00.910 NOWAK, MARYALICE And you can't see on your screen now a few tips 00:01:00.910 --> 00:01:03.950 for hopefully getting the most out of your teams experience today. 00:01:05.025 --> 00:01:07.120 NOWAK, MARYALICE 1st, If you find you have questions, 00:01:07.120 --> 00:01:09.840 they come up during the webinar, you can type them 00:01:09.840 --> 00:01:14.120 into the chat box and you can see that icon at the top middle 00:01:14.120 --> 00:01:17.680 of your screen and what I'm thinking is that I'll hold off 00:01:17.680 --> 00:01:21.000 on answering questions until the end of my presentation, 00:01:21.000 --> 00:01:23.375 but this way they'll be recorded so I can be sure 00:01:23.375 --> 00:01:25.890 to circle back to all of them. 00:01:25.890 --> 00:01:28.970 NOWAK, MARYALICE And then just to the right of the chat icon, 00:01:28.970 --> 00:01:32.620 you'll see the razor hand icon, but again, probably better 00:01:32.620 --> 00:01:36.840 to use the chat box so that I can just scroll back through the presentation 00:01:36.840 --> 00:01:38.050 through the questions at the end. 00:01:38.050 --> 00:01:43.920 It's kind of also we can enlarge the PowerPoint by clicking on the ellipsis. 00:01:43.920 --> 00:01:48.750 Those three dots and then either on the focus on content 00:01:48.750 --> 00:01:53.900 or full screen options you can get off that menu or you can use both of those 00:01:53.900 --> 00:01:55.500 at the same time to maximize the size. 00:01:55.500 --> 00:01:56.890 NOWAK, MARYALICE The size of the PowerPoint. 00:01:58.150 --> 00:02:00.350 NOWAK, MARYALICE And then finally, if anyone has a need 00:02:00.350 --> 00:02:05.570 for closed captioning, you can simply click on turn on live captions, 00:02:05.570 --> 00:02:10.220 which is also available a little further down on that list. 00:02:10.220 --> 00:02:12.020 OK, so with that covered. 00:02:13.010 --> 00:02:16.520 NOWAK, MARYALICE You can see here on this next slide, 00:02:16.520 --> 00:02:20.790 both the CBP mission statement and all the also the mission statement 00:02:20.790 --> 00:02:22.940 of the opposite trade, which is the office 00:02:22.940 --> 00:02:26.660 that the national Commodity Specialists Division falls under. 00:02:26.660 --> 00:02:31.000 So what our division is looking to do with our webinar series is really we're 00:02:31.000 --> 00:02:33.950 just doing our part to facilitate legitimate trade. 00:02:35.025 --> 00:02:37.990 NOWAK, MARYALICE Which then feeds into the larger city Commission 00:02:37.990 --> 00:02:40.430 of enhancing our nation's economic security. 00:02:41.650 --> 00:02:43.660 NOWAK, MARYALICE OK. 00:02:43.660 --> 00:02:46.780 NOWAK, MARYALICE So then Next up, I do need to call your attention 00:02:46.780 --> 00:02:49.640 to the disclaimer you see on this slide. 00:02:49.640 --> 00:02:52.640 Now those of you who have joined us for previous webinars 00:02:52.640 --> 00:02:55.110 will have seen this disclaimer already. 00:02:55.110 --> 00:02:59.330 But for anyone who has it, basically what this slide says is 00:02:59.330 --> 00:03:02.160 that the information I'll be covering today is for training 00:03:02.160 --> 00:03:05.670 and educational purposes, but it is advisory only 00:03:05.670 --> 00:03:07.070 and can't be considered binding. 00:03:08.525 --> 00:03:10.870 NOWAK, MARYALICE Changes to our laws and regulations can occur 00:03:10.870 --> 00:03:14.990 in any time and has no there have been quite a few changes to this year. 00:03:14.990 --> 00:03:16.460 I'll be talking about some of them today 00:03:17.770 --> 00:03:20.281 and customs issues can become complicated, 00:03:20.282 --> 00:03:25.050 so it's it's always a good idea to think about requesting the binding concerns. 00:03:26.525 --> 00:03:29.750 NOWAK, MARYALICE And next I also need to mention 00:03:29.750 --> 00:03:33.900 that I have included some images of garments in my presentation today, 00:03:33.900 --> 00:03:37.670 photos, drawings and these images have been obtained 00:03:37.670 --> 00:03:42.430 and included here legally, but again only for educational purposes and to 00:03:42.430 --> 00:03:46.500 and to illustrate the specific features I'll be discussing. 00:03:46.500 --> 00:03:50.130 But they are not intended for further copying or distribution 00:03:50.130 --> 00:03:51.260 beyond what you see here. 00:03:53.570 --> 00:03:57.500 NOWAK, MARYALICE That being said, on this webinar is being recorded today 00:03:57.500 --> 00:04:02.710 and it will be posted on to the CBT website in the not too distant future 00:04:02.710 --> 00:04:04.990 and the link you can see here on this screen. 00:04:04.990 --> 00:04:08.270 NOWAK, MARYALICE I'm not sure exactly what the time frame is 00:04:08.270 --> 00:04:12.820 as far as posting webinars, but I'd say probably give it a few weeks at least. 00:04:12.820 --> 00:04:13.500 OK. 00:04:13.500 --> 00:04:16.690 NOWAK, MARYALICE And I'll give you a moment to write down this link, 00:04:16.690 --> 00:04:19.180 and while you're writing, I just wanted to also let you know. 00:04:20.750 --> 00:04:23.380 NOWAK, MARYALICE This link will also take you to other webinars 00:04:23.380 --> 00:04:27.210 that are our division has presented over the past few years 00:04:27.210 --> 00:04:30.380 and they're organized by the different industries that are represented 00:04:30.380 --> 00:04:33.570 by CBP Centers of Excellence and expertise. 00:04:33.570 --> 00:04:36.398 And we're actually putting together a pretty extensive library 00:04:36.399 --> 00:04:37.340 of webinars here. 00:04:38.650 --> 00:04:40.620 NOWAK, MARYALICE And in addition to other webinars, 00:04:40.620 --> 00:04:45.150 there's also a presentation I noticed now protests one on US, 00:04:45.150 --> 00:04:50.020 MCA that had been presented by other divisions within the odds trade. 00:04:50.020 --> 00:04:52.450 But really I encourage you to browse through these 00:04:52.450 --> 00:04:55.750 when you have a few minutes and see what other helpful information you 00:04:55.750 --> 00:04:56.750 might be able to find. 00:04:58.430 --> 00:04:59.040 NOWAK, MARYALICE OK. 00:04:59.040 --> 00:05:00.250 And then? 00:05:00.250 --> 00:05:00.934 NOWAK, MARYALICE Finally, 00:05:00.935 --> 00:05:03.800 since I just mentioned our binding rulings program. 00:05:03.800 --> 00:05:08.670 NOWAK, MARYALICE This slide shows you where to go on CD's website 00:05:08.670 --> 00:05:12.000 to get information on how to obtain a binding. 00:05:12.000 --> 00:05:13.510 NOWAK, MARYALICE Like that and I'll give you a moment 00:05:13.510 --> 00:05:15.660 to Jack this down as well. 00:05:15.660 --> 00:05:18.498 I'll also be putting up my contact information 00:05:18.499 --> 00:05:20.430 at the end of the presentation, 00:05:20.430 --> 00:05:23.790 so that if you have any questions about the binding ruins program 00:05:23.790 --> 00:05:27.500 or if questions come up later about anything that I'm going 00:05:27.500 --> 00:05:30.290 to be covering today, you'll know how to get in touch with me. 00:05:31.650 --> 00:05:34.310 NOWAK, MARYALICE OK, so with all the preliminaries out 00:05:34.310 --> 00:05:38.060 of the way, I'm going to get started on today's topic, 00:05:38.060 --> 00:05:43.100 which is the 2022 changes to the harmonized tariff schedule 00:05:43.100 --> 00:05:45.730 and specifically how these changes impact beds. 00:05:48.025 --> 00:05:52.100 NOWAK, MARYALICE And as you can see, I have subtitled this webinar Much Ado 00:05:52.100 --> 00:05:56.300 about nearly none and just so you know, I actually came up 00:05:56.300 --> 00:05:59.450 with this subtitle pretty early on and I was turning it over 00:05:59.450 --> 00:06:02.180 in my mind for a for a little while and I was thinking, 00:06:02.180 --> 00:06:04.280 should I really call it that because I don't know. 00:06:04.280 --> 00:06:07.670 We could sounds kind of flippant, but it is pretty accurate. 00:06:07.670 --> 00:06:08.890 So I was out of the sand. 00:06:09.990 --> 00:06:13.130 NOWAK, MARYALICE But that my colleague NIS Antoinette Williams 00:06:13.130 --> 00:06:18.820 presented her webinar last month and she called it blouses to be or not. 00:06:20.030 --> 00:06:21.600 And I was like, well, that's it. 00:06:21.600 --> 00:06:22.620 It's meant to be. 00:06:22.620 --> 00:06:25.270 So we're gonna have a little Shakespeare thing going on here. 00:06:25.270 --> 00:06:27.230 So just so everyone's aware. 00:06:27.230 --> 00:06:30.760 NOWAK, MARYALICE But really, I do think this title gets 00:06:30.760 --> 00:06:33.790 to the main point that I'd like to get across to you today. 00:06:33.790 --> 00:06:37.850 NOWAK, MARYALICE Which is granted, there have been some changes 00:06:37.850 --> 00:06:41.630 to the tariff schedule this year that affect men's governments. 00:06:41.630 --> 00:06:46.140 NOWAK, MARYALICE But other changes, we chapter notes and so forth. 00:06:46.140 --> 00:06:49.900 If you really take them apart and read them closely, 00:06:49.900 --> 00:06:54.510 they actually don't resolve in a lot of changes. 00:06:54.510 --> 00:06:55.810 For the governments that I handle. 00:06:57.400 --> 00:06:59.670 NOWAK, MARYALICE But just seeing the changes included 00:06:59.670 --> 00:07:02.200 in the tariffs schedule in the way that they did it, 00:07:02.200 --> 00:07:05.010 they can cause some confusion. 00:07:05.010 --> 00:07:06.390 NOWAK, MARYALICE And I think sometimes it 00:07:06.390 --> 00:07:10.100 might look like something has changed when it really hasn't. 00:07:10.100 --> 00:07:14.200 And I actually been getting questions on what these changes mean 00:07:14.200 --> 00:07:17.360 for men's garments for probably close to a year now. 00:07:18.813 --> 00:07:21.010 NOWAK, MARYALICE So the approach I thought I'd take today is 00:07:21.010 --> 00:07:23.510 to go over these changes 1 by 1. 00:07:23.510 --> 00:07:25.020 NOWAK, MARYALICE And kind of unpack them. 00:07:25.020 --> 00:07:28.480 Take a look at what each one of them means specifically 00:07:28.480 --> 00:07:30.500 for when's governments OK? 00:07:31.555 --> 00:07:34.210 NOWAK, MARYALICE And so here is the agenda for today. 00:07:35.200 --> 00:07:38.900 And as you can see, we're going to be working our way backwards 00:07:38.900 --> 00:07:42.030 through the tariff schedule to take a look at these changes. 00:07:42.030 --> 00:07:47.630 So I'm going to start off by discussing the new notes 4 to chapter 62. 00:07:47.630 --> 00:07:52.300 And that's because this is really the only change that affects men's garments. 00:07:53.610 --> 00:07:55.160 NOWAK, MARYALICE After that, I'm going to move on 00:07:55.160 --> 00:07:59.750 and take a look at the new Note 4, Chapter 61 and show you 00:07:59.750 --> 00:08:03.880 how really this note does not result in any changes 00:08:03.880 --> 00:08:06.125 to how we classify those governments. 00:08:07.275 --> 00:08:09.400 NOWAK, MARYALICE And then I'm also going to take a look 00:08:09.400 --> 00:08:13.020 at the new Note 15 to section 11 of the tariff schedule 00:08:13.020 --> 00:08:15.900 and that's the textiles and apparel section. 00:08:15.900 --> 00:08:20.480 And I'm gonna talk a little bit about how really there's nothing new here. 00:08:21.347 --> 00:08:24.750 NOWAK, MARYALICE OK, so with that I am going to get started. 00:08:26.227 --> 00:08:29.130 NOWAK, MARYALICE And here you can see the new Note 4, 00:08:29.130 --> 00:08:31.980 two chapter 62 in its entirety. 00:08:31.980 --> 00:08:35.230 NOWAK, MARYALICE Now this is a completely new note. 00:08:35.230 --> 00:08:39.210 No part of this note appeared as a chapter note in previous versions 00:08:39.210 --> 00:08:40.550 of the Harmonized tariff schedule. 00:08:41.566 --> 00:08:45.940 NOWAK, MARYALICE So whereas we used to enter 9 chapters notes in chapter 61. 00:08:45.940 --> 00:08:47.850 Now I'm sorry, chapter 62. 00:08:47.850 --> 00:08:49.250 Now we have 10. 00:08:49.250 --> 00:08:52.400 NOWAK, MARYALICE And so this note was inserted in heading order 00:08:52.400 --> 00:08:58.030 as Note 4 and then all of the subsequent nodes were moved down. 00:08:58.788 --> 00:09:01.610 NOWAK, MARYALICE So next, let's deconstruct this down, Shelly. 00:09:02.977 --> 00:09:05.270 NOWAK, MARYALICE And here I've highlighted the portion 00:09:05.270 --> 00:09:09.400 of the first change that deals with heading to 6205, 00:09:09.400 --> 00:09:12.530 which provides for Mens or boys shirts. 00:09:13.889 --> 00:09:16.630 NOWAK, MARYALICE And this change has to do with pockets below the waist. 00:09:17.820 --> 00:09:22.420 So as you can see, men's shirts that have pockets below the waist 00:09:22.420 --> 00:09:26.500 are now excluded from classification in heading 60 through offline. 00:09:28.133 --> 00:09:29.470 NOWAK, MARYALICE And this is a change 00:09:29.470 --> 00:09:34.320 because previously pockets below the waist were allowed up were allowed 00:09:34.320 --> 00:09:35.210 on these garments. 00:09:35.687 --> 00:09:40.130 NOWAK, MARYALICE Specifically, the explanatory note to 6205, 00:09:40.130 --> 00:09:43.790 which you'll remember the explanatory notes aren't legally binding, 00:09:43.790 --> 00:09:47.310 but they do constitute the official interpretation 00:09:47.310 --> 00:09:50.370 of the harmonized tariff schedule at the international level. 00:09:52.237 --> 00:09:57.580 NOWAK, MARYALICE Explanatory note to 6205 does allow the pockets pockets 00:09:57.580 --> 00:10:01.390 below the waist for, provided that the government does not exhibit 00:10:01.390 --> 00:10:03.810 what it calls the character of a jacket. 00:10:04.740 --> 00:10:07.615 NOWAK, MARYALICE So the change is subtle here, but it is a change. 00:10:08.740 --> 00:10:11.150 NOWAK, MARYALICE Now a lot of you are probably wondering 00:10:11.150 --> 00:10:15.450 about the reason for this, so I did a little research 00:10:15.450 --> 00:10:19.870 and what I learned is that this was a proposal that dates back 00:10:19.870 --> 00:10:25.600 to 2013 when a member of, and here's about for you, 00:10:25.600 --> 00:10:30.490 the world customs Organizations Harmonized Review Subcommittee. 00:10:30.490 --> 00:10:33.040 So we'll just call it the RC. 00:10:33.040 --> 00:10:37.010 NOWAK, MARYALICE So a member of the RC suggested this change 00:10:37.010 --> 00:10:43.650 in order to make the classification of woven shirts of 6205 consistent 00:10:43.650 --> 00:10:47.160 with their knit counterparts of 6105. 00:10:48.629 --> 00:10:52.520 NOWAK, MARYALICE Because pockets below the waist are not permitted shirts 00:10:52.520 --> 00:10:58.710 of 6105, and that's perfect for Chapter Note 4 to chapter 61 of the schedule. 00:11:00.124 --> 00:11:02.526 NOWAK, MARYALICE And also the explanatory note 00:11:02.527 --> 00:11:06.020 to 6105 provides guidance to that effect, which I've listed here. 00:11:08.766 --> 00:11:14.050 NOWAK, MARYALICE And in addition to making 6205 and 6105 more consistent. 00:11:15.128 --> 00:11:20.130 NOWAK, MARYALICE This change also makes men's garments of 6205 consistent 00:11:20.130 --> 00:11:22.940 with their women's counterparts of hitting 62. 00:11:22.940 --> 00:11:23.280 Oh cents. 00:11:24.053 --> 00:11:27.360 NOWAK, MARYALICE Because and you can also see here 00:11:27.360 --> 00:11:32.040 the explanatory known state that pockets below the waist are not permitted 00:11:32.040 --> 00:11:34.590 on women's garments of 6206. 00:11:35.934 --> 00:11:37.088 NOWAK, MARYALICE And it's my understanding 00:11:37.089 --> 00:11:39.500 that the United States was aware of the change. 00:11:39.500 --> 00:11:45.590 This would mean more the classification of governance of 6205 going forward, 00:11:45.590 --> 00:11:49.300 but they agreed to the proposal for the sake of consistency 00:11:49.300 --> 00:11:52.890 and for a simpler, maybe a little more common sense approach 00:11:52.890 --> 00:11:55.580 to the classification of similar governments. 00:11:57.619 --> 00:12:01.440 NOWAK, MARYALICE But an important point I wanted to bring about bring up 00:12:01.440 --> 00:12:04.920 with this respect to this change and this is a question I've got with you. 00:12:04.920 --> 00:12:09.300 Times from the trade is that any previously issued rulings 00:12:09.301 --> 00:12:13.480 that are affected by this change will be revoked 00:12:13.481 --> 00:12:16.380 by what we call operation of law. 00:12:17.890 --> 00:12:20.820 NOWAK, MARYALICE And what this means is that CDP does not need 00:12:20.820 --> 00:12:23.910 to take any action in order to revoke these rulings. 00:12:24.970 --> 00:12:26.670 NOWAK, MARYALICE The new chapter node is a change 00:12:26.670 --> 00:12:29.280 to the legal text of the tariff schedule. 00:12:29.280 --> 00:12:30.890 The chapter notes had Google stats. 00:12:32.023 --> 00:12:34.970 NOWAK, MARYALICE Therefore, any rulings that are affected 00:12:34.970 --> 00:12:37.740 by this change will just automatically be remote. 00:12:39.381 --> 00:12:42.220 NOWAK, MARYALICE Now this doesn't mean that previous imports 00:12:42.220 --> 00:12:44.280 of these governments were not compliant. 00:12:44.280 --> 00:12:48.990 But going forward, if men shirts that had been classified 00:12:48.990 --> 00:12:55.500 in 6205 have pockets below the waist, you can no longer use these rulings 00:12:55.500 --> 00:12:57.970 to support a 6205 classification. 00:12:59.020 --> 00:13:02.560 NOWAK, MARYALICE Now, if you like, if you're still importing these garments, 00:13:02.560 --> 00:13:05.860 you have the option to request a new ruling on them, 00:13:05.860 --> 00:13:08.250 but the previous ruling would no longer be valid. 00:13:09.525 --> 00:13:10.422 NOWAK, MARYALICE Hi. 00:13:12.250 --> 00:13:16.800 NOWAK, MARYALICE So then next I would like to move on to the next part 00:13:16.800 --> 00:13:22.550 of the new chapter mode and how this change will affect governance sixty 2/5. 00:13:22.550 --> 00:13:25.970 NOWAK, MARYALICE And this is similar to the change I talked just talked about 00:13:25.970 --> 00:13:30.220 and this one has to do with governments that have tightening at the bottom. 00:13:30.220 --> 00:13:34.625 NOWAK, MARYALICE And so as you can see on this slide. 00:13:34.625 --> 00:13:36.540 NOWAK, MARYALICE Governments with the ribbed waistband 00:13:36.540 --> 00:13:40.900 or with any other type of tightening at the bottom are now excluded 00:13:40.900 --> 00:13:42.300 from heading 6205. 00:13:43.594 --> 00:13:46.820 NOWAK, MARYALICE And this is also a departure from how we used 00:13:46.820 --> 00:13:47.820 to classify discoveries. 00:13:49.050 --> 00:13:52.820 As you can see here, prior to 2022, this kind 00:13:52.820 --> 00:13:54.719 of tightening was permitted for governments 00:13:54.719 --> 00:13:57.750 of 6205 under certain circumstances. 00:13:58.810 --> 00:14:03.370 NOWAK, MARYALICE Specifically for the explanatory note, two 6205. 00:14:04.151 --> 00:14:07.510 NOWAK, MARYALICE Tightening at the bottom of the Garmin was allowed, 00:14:07.510 --> 00:14:12.180 provided that the government did not exhibit the character of a windcheater 00:14:12.180 --> 00:14:13.250 or wind jacket. 00:14:13.250 --> 00:14:16.450 So basically outerwear type garments. 00:14:16.450 --> 00:14:19.710 Again, the change is subtle, but it is a change. 00:14:21.870 --> 00:14:24.690 NOWAK, MARYALICE But you know, I think I should also mention 00:14:24.690 --> 00:14:29.350 that I don't personally see this particular changes having a huge effect 00:14:29.350 --> 00:14:33.030 in how we will classify these governments and maybe some 00:14:33.030 --> 00:14:34.510 of you out there can enlighten me. 00:14:34.510 --> 00:14:38.770 But in my time as an NIS, which is almost seven years now, 00:14:38.770 --> 00:14:42.450 I've seen almost no man's world which shirts that have tightening 00:14:42.450 --> 00:14:43.830 at the bottom. 00:14:43.830 --> 00:14:46.010 NOWAK, MARYALICE And here is included a photograph 00:14:46.010 --> 00:14:48.420 of really the only one I could find. 00:14:48.420 --> 00:14:52.520 But practically speaking, this feature seems to be a lot more common 00:14:52.520 --> 00:14:57.010 on pictures than I will returns, at least for that. 00:14:57.010 --> 00:14:58.840 NOWAK, MARYALICE And. 00:14:58.840 --> 00:15:01.420 NOWAK, MARYALICE Here I've included some information 00:15:01.420 --> 00:15:05.220 on the thinking behind this change, so I'd like to change 00:15:05.220 --> 00:15:07.280 to pockets below the waist. 00:15:07.280 --> 00:15:11.380 The idea here was to again to try to make the classification 00:15:11.380 --> 00:15:16.700 of events overtures of 62, five more consistent 00:15:16.700 --> 00:15:20.660 with how we classify vents mixtures of 6105. 00:15:22.355 --> 00:15:23.860 NOWAK, MARYALICE Which as you can see here, 00:15:23.860 --> 00:15:28.910 both Chapter Note 4 to the tariff schedule and the explanatory note 00:15:28.910 --> 00:15:34.580 to heading 6105 categorically excludes garments with tightening 00:15:34.580 --> 00:15:35.560 at the bottom. 00:15:35.560 --> 00:15:37.690 No exceptions, just across the board. 00:15:40.018 --> 00:15:42.150 NOWAK, MARYALICE And this change will also make the way 00:15:42.150 --> 00:15:45.120 we classify men's guards more consistent 00:15:45.120 --> 00:15:48.600 with the way we classify women's talents. 00:15:48.600 --> 00:15:52.950 And that's because the explanatory note, depending 62 cents, 00:15:52.950 --> 00:15:55.280 excludes governments with tightening at the bottom. 00:15:57.598 --> 00:15:59.349 NOWAK, MARYALICE So overall, 00:15:59.350 --> 00:16:03.080 hopefully again this will mean a simpler, 00:16:03.080 --> 00:16:07.450 cleaner approach to the classification of similar governments, 00:16:07.450 --> 00:16:13.960 6205 versus 6105 and 6205 versus 6206. 00:16:14.794 --> 00:16:15.567 NOWAK, MARYALICE What? 00:16:17.060 --> 00:16:19.460 NOWAK, MARYALICE And then finally, again, as you can see 00:16:19.460 --> 00:16:23.530 on the bottom of this slide, any previous rulings that are affected 00:16:23.530 --> 00:16:27.380 by this change will be revoked by operation of law. 00:16:29.130 --> 00:16:33.060 NOWAK, MARYALICE And then just to finish up with Note 4, 00:16:33.060 --> 00:16:38.400 to check 62, I thought I would just quickly review the remaining parts 00:16:38.400 --> 00:16:43.220 of this new note as they apply to heading 6205 W garments 00:16:44.260 --> 00:16:47.861 and really at least as far as men's governments go, 00:16:47.862 --> 00:16:49.730 there are no changes here. 00:16:49.730 --> 00:16:52.150 NOWAK, MARYALICE This additional language that was added 00:16:52.150 --> 00:16:57.480 to the node is just a reflection of the RC's desire to include a list 00:16:57.480 --> 00:17:00.140 of some of the characteristics of governments of these hearings. 00:17:01.913 --> 00:17:04.250 NOWAK, MARYALICE And as most of you are probably aware, 00:17:04.250 --> 00:17:10.430 this same paragraph also appears in the new chapter known for Chapter 61, 00:17:10.430 --> 00:17:12.690 which I'm going to be going over in a few minutes. 00:17:13.840 --> 00:17:19.120 NOWAK, MARYALICE So really, as I said, as far as Henning 6205 goes, 00:17:19.120 --> 00:17:24.750 this part of the new Note, Chapter 62 makes no changes to comments. 00:17:24.750 --> 00:17:25.890 Governments are classified. 00:17:27.359 --> 00:17:30.030 NOWAK, MARYALICE And on this line what I've done is just sort 00:17:30.030 --> 00:17:33.440 of unpack this list of features and I highlighted the portions 00:17:33.440 --> 00:17:39.080 that pertain to heading 6205 to show you that really this is business 00:17:39.080 --> 00:17:42.070 in future work there so. 00:17:42.070 --> 00:17:44.730 NOWAK, MARYALICE Here you see in the first bullet 00:17:44.730 --> 00:17:49.900 that the new Note states pending 6205 does not cover sleeve with skyrims. 00:17:51.127 --> 00:17:52.850 NOWAK, MARYALICE There's no change here. 00:17:52.850 --> 00:17:57.680 This has already been true through the explanatory notice 6205, 00:17:57.680 --> 00:18:01.370 which states that sleeveless garments are excluded from this head. 00:18:02.275 --> 00:18:04.300 NOWAK, MARYALICE And. 00:18:04.300 --> 00:18:08.230 NOWAK, MARYALICE And then next the new note goes on to talk about 00:18:08.230 --> 00:18:12.620 some of the other features of governments of 6205 and 6206. 00:18:13.525 --> 00:18:15.560 NOWAK, MARYALICE But again, I'm only concerned with men. 00:18:15.560 --> 00:18:20.120 Shirts of 6205 here, because wasn't shirt, blouses are ribbons, 00:18:20.120 --> 00:18:22.280 governments and therefore they are not my life. 00:18:23.420 --> 00:18:27.950 NOWAK, MARYALICE So the note defines shirts as garments designed 00:18:27.950 --> 00:18:30.110 to cover the upper part of the body. 00:18:30.110 --> 00:18:34.410 Having longer short sleeves and a full or partial opening starting 00:18:34.410 --> 00:18:34.990 at the neckline. 00:18:36.685 --> 00:18:40.780 NOWAK, MARYALICE Again, this doesn't change anything for governments of 6205. 00:18:40.780 --> 00:18:44.670 NOWAK, MARYALICE All of this has already applied to that shirt. 00:18:44.670 --> 00:18:49.690 NOWAK, MARYALICE And in fact, this part of the new note was taken verbatim 00:18:49.690 --> 00:18:53.100 from the general explanatory note to chapter 62. 00:18:55.241 --> 00:18:59.440 NOWAK, MARYALICE And then finally, the last sentence of the new note says 00:18:59.440 --> 00:19:00.970 that shirts may also have a color. 00:19:02.564 --> 00:19:04.750 NOWAK, MARYALICE Now I'm pretty sure most of you are surprised 00:19:04.750 --> 00:19:08.850 to hear this news, but again, there is no change here. 00:19:08.850 --> 00:19:13.810 Dress shirts or shirts and so forth and all had collars for many years 00:19:13.810 --> 00:19:16.620 and we have classified them in 6205. 00:19:18.420 --> 00:19:22.690 NOWAK, MARYALICE That means said, the insertion of this language here 00:19:22.690 --> 00:19:29.630 in Chapter 62 does reflect the language of the of the general explanatory note 00:19:29.630 --> 00:19:34.875 to chapter 61, which says sure it's mail, so first power. 00:19:36.758 --> 00:19:40.870 NOWAK, MARYALICE And so again, you can see that although we might take it 00:19:40.870 --> 00:19:44.150 for granted that, yes, well, of course, shirts can have collars. 00:19:44.916 --> 00:19:48.330 NOWAK, MARYALICE As far as I've been able to find, the decision 00:19:48.330 --> 00:19:52.790 to include this sentence here is simply another attempt 00:19:52.790 --> 00:19:57.560 to promote a more consistent and uniform approach to the classification 00:19:57.560 --> 00:20:01.780 of similar governments, whether they are met or women. 00:20:03.650 --> 00:20:08.830 NOWAK, MARYALICE And with that, that is all I have as far as the new note, 00:20:08.830 --> 00:20:10.030 two chapter 62. 00:20:12.211 --> 00:20:14.940 NOWAK, MARYALICE But as I promised, now I'm going to move on 00:20:14.940 --> 00:20:17.670 to the new note to Chapter 61. 00:20:20.525 --> 00:20:25.580 NOWAK, MARYALICE And as I said, this new note to chapter 61 makes no changes 00:20:25.580 --> 00:20:26.830 as far as men's. 00:20:26.830 --> 00:20:30.080 Did it work or change shirts of men, 6105? 00:20:31.361 --> 00:20:33.370 NOWAK, MARYALICE But also as I mentioned earlier, 00:20:33.370 --> 00:20:36.110 I think it's still important to spend some time on this today. 00:20:36.110 --> 00:20:39.540 NOWAK, MARYALICE Because the way this note is written, 00:20:39.540 --> 00:20:45.680 in particular the way it talks about governments of both 6105 and 6106, 00:20:45.680 --> 00:20:48.250 at the same time, even in the same sentence. 00:20:49.734 --> 00:20:51.870 NOWAK, MARYALICE The result of this is that I don't think 00:20:51.870 --> 00:20:56.200 it's immediately clear what has actually changed and what hasn't. 00:20:56.200 --> 00:20:58.430 NOWAK, MARYALICE And from the questions I've been getting 00:20:58.430 --> 00:21:02.790 from a lot of you, I think it's safe to say that this is causing a fair amount 00:21:02.790 --> 00:21:05.947 of confusion, not just about women's garments, 00:21:05.948 --> 00:21:08.230 but about man's garments as well. 00:21:08.230 --> 00:21:11.130 And I think it's maybe leading to a misconception 00:21:11.130 --> 00:21:15.590 that there's no changes things for men's governments that it really doesn't. 00:21:16.731 --> 00:21:19.240 NOWAK, MARYALICE And so my intention in this next part 00:21:19.240 --> 00:21:22.500 of the presentation is to review the node. 00:21:22.500 --> 00:21:22.960 NOWAK, MARYALICE Really. 00:21:22.960 --> 00:21:28.200 Take a good look at it and take it apart and separate what it says about vents. 00:21:28.200 --> 00:21:33.860 Governments of 6105 for what it says about women's governments of 6106. 00:21:36.165 --> 00:21:39.010 NOWAK, MARYALICE So once thought I'd start out by well, 00:21:39.010 --> 00:21:44.530 first taking a look at this node in its rather overwhelming entirety, 00:21:44.530 --> 00:21:47.150 and you can see the whole note here. 00:21:47.150 --> 00:21:50.770 NOWAK, MARYALICE But then, starting with the next slide on, 00:21:50.770 --> 00:21:52.960 we're going to deconstruct this node as well. 00:21:54.350 --> 00:21:57.560 So first, I have included a little cut and paste 00:21:57.560 --> 00:22:01.470 from the tariff schedule that shows the article description. 00:22:02.181 --> 00:22:05.940 NOWAK, MARYALICE Before heading 6105 so that everyone is clear 00:22:05.940 --> 00:22:09.340 on precisely what types of governments I'm talking about. 00:22:09.903 --> 00:22:11.250 NOWAK, MARYALICE So as you can see, 00:22:11.250 --> 00:22:16.280 heading 6105 covers bends or boys shirts. 00:22:16.280 --> 00:22:17.250 NOWAK, MARYALICE That's it. 00:22:18.560 --> 00:22:20.740 NOWAK, MARYALICE And then as far as the first paragraph 00:22:20.740 --> 00:22:26.230 of the new node, what you might notice is that it is exactly word 00:22:26.230 --> 00:22:31.310 for word the same as the old notes for the Chapter 61 that appeared 00:22:31.310 --> 00:22:33.775 in previous versions of the tariff schedule. 00:22:35.430 --> 00:22:37.350 NOWAK, MARYALICE And so just like the old node 00:22:37.350 --> 00:22:41.360 for this new note says that heading 6105. 00:22:42.423 --> 00:22:43.750 NOWAK, MARYALICE Doesn't include governments 00:22:43.750 --> 00:22:45.275 with pockets below the waste. 00:22:45.750 --> 00:22:48.290 NOWAK, MARYALICE Our governments, with a ribbon and waistband 00:22:48.290 --> 00:22:51.430 or other means of tightening at the bottom 00:22:51.430 --> 00:22:56.000 and there's a stitch count requirement that's also the same as the filled out. 00:22:58.125 --> 00:23:02.340 NOWAK, MARYALICE So what does this first paragraph of the new node mean 00:23:02.340 --> 00:23:07.280 for how we will classify Mens shirts of panic 6105 going forward? 00:23:08.546 --> 00:23:10.470 NOWAK, MARYALICE The answer is nothing. 00:23:10.470 --> 00:23:16.400 This first paragraph changes not this thing as far as men shirts go, alright? 00:23:17.939 --> 00:23:19.990 NOWAK, MARYALICE So next let's move on to the rest of the house. 00:23:23.025 --> 00:23:25.470 NOWAK, MARYALICE And as you can see here, 00:23:25.470 --> 00:23:30.160 this new note Chapter 61 includes a second paragraph that talks 00:23:30.160 --> 00:23:34.010 about the different features of shirts, gloves, and then shirt blouses. 00:23:34.666 --> 00:23:38.000 NOWAK, MARYALICE And what might jump out at you right off the top is 00:23:38.000 --> 00:23:43.080 that this second paragraph is exactly word for word, 00:23:43.080 --> 00:23:48.160 the same as the second paragraph of the new node to chapter 62 00:23:48.160 --> 00:23:49.330 that we just went over. 00:23:50.971 --> 00:23:52.470 NOWAK, MARYALICE So again, and you're going 00:23:52.470 --> 00:23:57.670 to notice the theme development here, it becomes clear that the overriding idea 00:23:57.670 --> 00:24:03.270 with these changes is to create a board uniform and consistent approach 00:24:03.270 --> 00:24:07.520 to the way we classify similar doubts, whether they are friends, 00:24:07.520 --> 00:24:11.150 governments or women's governments and whether they are met or women. 00:24:12.170 --> 00:24:15.009 And so this identical repetitive language serves 00:24:15.010 --> 00:24:16.690 as further evidence of this. 00:24:18.730 --> 00:24:21.190 NOWAK, MARYALICE And I've highlighted the references to shirts 00:24:21.190 --> 00:24:25.290 and both notes to reinforce that I'm talking only about shirts here. 00:24:25.290 --> 00:24:28.720 NOWAK, MARYALICE And that's because of the three types of garments 00:24:28.720 --> 00:24:30.810 that are mentioned in these nodes. 00:24:30.810 --> 00:24:33.600 Shirts are the only ones that are experiments, 00:24:33.600 --> 00:24:35.590 and thus the only ones I've ever done. 00:24:35.590 --> 00:24:37.690 NOWAK, MARYALICE OK. 00:24:37.690 --> 00:24:40.770 NOWAK, MARYALICE So next, let's take a little closer look 00:24:40.770 --> 00:24:45.250 at this second paragraph, again, with an emphasis only on what it has 00:24:45.250 --> 00:24:46.830 to say about shirts. 00:24:47.541 --> 00:24:52.510 NOWAK, MARYALICE So again, as we saw with men's overshirts of headings 6205. 00:24:53.526 --> 00:24:58.710 NOWAK, MARYALICE Mens Nike shirts of heading 6105 are designed 00:24:58.710 --> 00:25:00.230 to cover the upper part of the body. 00:25:01.269 --> 00:25:02.780 NOWAK, MARYALICE Take water short sleeves. 00:25:04.150 --> 00:25:06.730 NOWAK, MARYALICE And they have a full or partial opening starting 00:25:06.730 --> 00:25:10.080 at the neckline, and they may have a collar. 00:25:11.025 --> 00:25:15.790 NOWAK, MARYALICE And also just like we saw with heading 6205, 00:25:15.790 --> 00:25:19.160 this list of shirt features is taken for being verbatim 00:25:19.160 --> 00:25:24.290 from the explanatory notes in this case specifically, you can find the language 00:25:24.290 --> 00:25:27.200 in the general explanatory note two chapter 61. 00:25:28.598 --> 00:25:30.217 NOWAK, MARYALICE And this is historically the guidance 00:25:30.218 --> 00:25:33.480 that we've relied on when classified these types of garments. 00:25:34.775 --> 00:25:35.540 NOWAK, MARYALICE Therefore. 00:25:35.540 --> 00:25:38.130 NOWAK, MARYALICE What is this second paragraph? 00:25:38.130 --> 00:25:40.550 This new part of Chapter 61? 00:25:40.550 --> 00:25:46.610 Note 4 being for how we will now classify men's garments of 6105. 00:25:48.774 --> 00:25:50.926 NOWAK, MARYALICE If you said nothing, you are correct. 00:25:54.275 --> 00:25:57.190 NOWAK, MARYALICE Yes, I've noticed here on the bottom of this slide, 00:25:57.190 --> 00:25:59.800 this new paragraph to the new node. 00:26:00.870 --> 00:26:05.480 NOWAK, MARYALICE Makes no changes to the way we classify and shirts of 6105. 00:26:07.738 --> 00:26:11.620 NOWAK, MARYALICE So is Iran hopefully been able to explain with respect 00:26:11.620 --> 00:26:16.490 to vent shirts of hitting 6105, the new Chapter Note 4 00:26:16.490 --> 00:26:20.850 to chapter 61 really is much to do about nothing. 00:26:20.850 --> 00:26:24.500 NOWAK, MARYALICE No, I apologize for not being able to find a picture 00:26:24.500 --> 00:26:28.930 that had adventured that clearly had an opening in the neckline. 00:26:28.930 --> 00:26:32.200 This this picture was the best I could do, but in vision, 00:26:32.200 --> 00:26:36.100 if you will and opening in the rear neckline in the upper body garment 00:26:36.100 --> 00:26:36.650 of her friend. 00:26:38.673 --> 00:26:41.690 NOWAK, MARYALICE But like I said, hopefully I've made my point, 00:26:41.690 --> 00:26:46.410 which is that it might look like a lot of changes are going on here. 00:26:46.410 --> 00:26:49.760 And with respect to women's garments, that is certainly true 00:26:49.760 --> 00:26:52.600 and those presents some supper challenges. 00:26:52.600 --> 00:26:58.470 But as far as my life, if you really review this node and pull out the cards 00:26:58.470 --> 00:27:01.875 that are relevant to men's shirts specifically, 00:27:01.875 --> 00:27:03.650 it really is it's symptoms. 00:27:03.651 --> 00:27:05.010 Well, OK. 00:27:06.180 --> 00:27:08.850 And here in this next slide, I thought I'd. 00:27:08.850 --> 00:27:09.530 NOWAK, MARYALICE Would not. 00:27:10.650 --> 00:27:13.600 NOWAK, MARYALICE Just include an example of what I mean by this. 00:27:13.600 --> 00:27:16.920 Now this is a question that came in from a member of the trade 00:27:18.040 --> 00:27:18.720 and the question is. 00:27:19.836 --> 00:27:23.350 NOWAK, MARYALICE Does the definition of blouse that is included 00:27:23.350 --> 00:27:26.890 in the new Note, Chapter 61 applied to men as well. 00:27:27.875 --> 00:27:31.150 NOWAK, MARYALICE Heading 6105 doesn't list blouses, just shirts. 00:27:32.275 --> 00:27:33.930 NOWAK, MARYALICE And you can see here some snippets 00:27:33.930 --> 00:27:38.960 from the tariff schedule that show headings 6105 and 6106 00:27:38.960 --> 00:27:40.830 and their article descriptions. 00:27:41.900 --> 00:27:45.630 NOWAK, MARYALICE So adding 6105 covers fence shirts 00:27:45.630 --> 00:27:50.420 while heading 6106 covers women's blouses and shirts. 00:27:52.025 --> 00:27:53.680 NOWAK, MARYALICE So what do you say? 00:27:53.680 --> 00:27:56.960 NOWAK, MARYALICE Does the definition of blouse that is now included 00:27:56.960 --> 00:28:02.260 in the new Chapter 61 no form applied to governments of 6105? 00:28:05.275 --> 00:28:07.780 NOWAK, MARYALICE Well, if you said no, you're correct 00:28:08.850 --> 00:28:14.640 because having 6105 does not provide for blouses, but only shirts. 00:28:14.640 --> 00:28:17.700 NOWAK, MARYALICE You don't need to be concerned about trying 00:28:17.700 --> 00:28:22.840 to apply a definition of blouse to garments of 6105. 00:28:25.025 --> 00:28:26.670 NOWAK, MARYALICE But this is what I mean about 00:28:26.670 --> 00:28:30.380 how this node can be confusing when you first look at it, 00:28:30.380 --> 00:28:33.150 and I think that has a lot to do with the way it starts out 00:28:33.150 --> 00:28:37.310 by talking about 6105 and 61 or 60 together. 00:28:37.310 --> 00:28:39.140 NOWAK, MARYALICE And I don't think 00:28:39.140 --> 00:28:42.140 that was necessarily a problem with the old node, 00:28:42.140 --> 00:28:45.380 but now that it's been expanded to talk about all the features 00:28:45.380 --> 00:28:47.650 of all the different governments, I think it kind 00:28:47.650 --> 00:28:49.645 of makes it look like all the information 00:28:49.646 --> 00:28:51.450 that's included applies to both pets. 00:28:53.150 --> 00:28:55.130 NOWAK, MARYALICE So it looks like these changes impact 00:28:55.130 --> 00:28:58.640 that may be classified, both events, garments and women's garments. 00:28:58.640 --> 00:29:02.400 NOWAK, MARYALICE But again, if you take the note of card 00:29:02.400 --> 00:29:05.450 and read it in conjunction with the specific garments 00:29:05.450 --> 00:29:11.770 that are provided for in adding 6105 and then heading 6106, 00:29:11.770 --> 00:29:14.210 I think things do become clearer. 00:29:14.210 --> 00:29:18.100 NOWAK, MARYALICE And if you try to do this and you're still confused 00:29:18.100 --> 00:29:21.420 because I think it can be overwhelming, please let me know 00:29:21.420 --> 00:29:23.400 and I will be happy to walk you through it. 00:29:23.400 --> 00:29:24.656 NOWAK, MARYALICE OK. 00:29:26.453 --> 00:29:36.130 NOWAK, MARYALICE So with that we are done with the new chapter notes. 00:29:36.130 --> 00:29:43.340 NOWAK, MARYALICE And take a look at note 15 to section 11 00:29:43.340 --> 00:29:45.000 of the tariff schedule. 00:29:45.000 --> 00:29:47.680 And again, this is the section that covers test out there. 00:29:47.680 --> 00:29:50.630 NOWAK, MARYALICE And this is also with you, 00:29:50.630 --> 00:29:53.770 though that was added to the 2022 terror. 00:29:53.770 --> 00:29:57.150 NOWAK, MARYALICE And as you can see this no deals with textiles 00:29:57.150 --> 00:30:02.560 and apparel that have other components incorporated into them, chemical, 00:30:02.560 --> 00:30:06.820 chemical, electronic that add extra functionality to goods. 00:30:08.648 --> 00:30:11.440 NOWAK, MARYALICE And what this note says is that these kinds 00:30:11.440 --> 00:30:16.360 of items remain classified in their respective headings in section 11. 00:30:17.600 --> 00:30:20.441 So for example, if you have an overall good 00:30:20.442 --> 00:30:22.830 that pertains electronic components, 00:30:22.830 --> 00:30:25.870 it would still be classified in Chapter 61 to 62. 00:30:26.867 --> 00:30:30.250 NOWAK, MARYALICE Provided that it's the apparel that imparts, 00:30:30.250 --> 00:30:33.773 he is such a character of the good, OK. 00:30:34.875 --> 00:30:37.780 NOWAK, MARYALICE So here's the question I'd like to address today, 00:30:37.780 --> 00:30:42.220 and this question actually also came in from someone in the trade community. 00:30:43.275 --> 00:30:45.100 NOWAK, MARYALICE What does this new note mean 00:30:45.100 --> 00:30:47.840 for the way we currently classify smarter now? 00:30:49.290 --> 00:30:52.420 NOWAK, MARYALICE And by now most of you are probably familiar 00:30:52.420 --> 00:30:53.670 with the term smart girl. 00:30:53.670 --> 00:30:58.730 But for those who might not be by smarter peril, I need apparel 00:30:58.730 --> 00:31:03.130 that has some sort of electronic component of the white wires attached 00:31:03.130 --> 00:31:03.850 to the government. 00:31:03.850 --> 00:31:08.580 Or maybe they're embedded right into the fabric and there might be sensors 00:31:08.580 --> 00:31:09.280 and so forth. 00:31:09.280 --> 00:31:13.170 And these components can enable the where to. 00:31:13.170 --> 00:31:15.050 NOWAK, MARYALICE To a variety of things. 00:31:15.050 --> 00:31:16.680 NOWAK, MARYALICE Measure their heart rate 00:31:16.680 --> 00:31:19.090 while they're working out breathing rate. 00:31:20.080 --> 00:31:21.570 Take a person's blood pressure. 00:31:21.570 --> 00:31:23.550 All these types of additional functionalities. 00:31:25.275 --> 00:31:25.980 NOWAK, MARYALICE And you can see here 00:31:25.980 --> 00:31:28.120 on your screen sounds down some Spartan girl. 00:31:30.400 --> 00:31:31.730 NOWAK, MARYALICE So what do you think? 00:31:31.730 --> 00:31:35.300 What does the new Note 15 mean for how we will classify these types 00:31:35.300 --> 00:31:37.240 of governments going forward? 00:31:37.240 --> 00:31:39.450 NOWAK, MARYALICE What time today? 00:31:40.191 --> 00:31:42.121 NOWAK, MARYALICE The answer is. 00:31:42.750 --> 00:31:43.480 NOWAK, MARYALICE Once again. 00:31:43.480 --> 00:31:49.640 NOWAK, MARYALICE I'm saying and the reason for this can actually be found 00:31:49.640 --> 00:31:51.350 in the new notice. 00:31:51.350 --> 00:31:53.200 NOWAK, MARYALICE Question that I've highlighted here. 00:31:55.516 --> 00:31:58.430 NOWAK, MARYALICE Because what this note essentially tells us 00:31:58.430 --> 00:31:59.970 is that items are Spartan. 00:31:59.970 --> 00:32:04.120 Carol are classified as apparel because goods of this section. 00:32:04.120 --> 00:32:06.775 NOWAK, MARYALICE 11 of the chair. 00:32:07.586 --> 00:32:11.280 NOWAK, MARYALICE So chapter 61 or two, chapter 62 for apparel. 00:32:12.650 --> 00:32:14.320 NOWAK, MARYALICE Long as it's to be apparel 00:32:14.320 --> 00:32:16.450 that imparts the essential character. 00:32:18.275 --> 00:32:20.270 NOWAK, MARYALICE But wait, essential character, 00:32:20.270 --> 00:32:23.640 wherever this term before isn't best gear, I agree. 00:32:26.900 --> 00:32:28.609 NOWAK, MARYALICE Well, yes it is. 00:32:28.875 --> 00:32:30.870 NOWAK, MARYALICE Yes, but you care is 3 says 00:32:30.870 --> 00:32:35.440 that when goods are prefacing classified under two or more headings 00:32:35.440 --> 00:32:40.590 and GRID 3B specifically talks about goods that have different components 00:32:40.590 --> 00:32:42.910 which are known as composite goods. 00:32:42.910 --> 00:32:45.340 NOWAK, MARYALICE And this is what we that was sparked girl, 00:32:45.340 --> 00:32:49.100 right, because these items include both apparel component 00:32:49.100 --> 00:32:51.150 and an electronic component. 00:32:52.400 --> 00:32:56.570 NOWAK, MARYALICE And so with GLR, I3B tells us is that these types 00:32:56.570 --> 00:33:00.290 of goods are to be classified according to the component 00:33:00.290 --> 00:33:02.680 that gives their essential character. 00:33:03.400 --> 00:33:08.789 NOWAK, MARYALICE This language to the language of the 15. 00:33:09.898 --> 00:33:14.610 NOWAK, MARYALICE GRI 3B refers to composite goods consisting 00:33:14.610 --> 00:33:15.870 of different components. 00:33:15.870 --> 00:33:19.280 NOWAK, MARYALICE Whereas the new Note 15 talks about governments. 00:33:19.280 --> 00:33:22.840 NOWAK, MARYALICE Incorporating electronic components 00:33:22.840 --> 00:33:26.354 for additional functionality now that sounds like a composite good, 00:33:26.355 --> 00:33:27.210 doesn't it? 00:33:28.000 --> 00:33:28.999 NOWAK, MARYALICE Then. 00:33:29.000 --> 00:33:32.730 NOWAK, MARYALICE GRI, 3B goes on to say that these types 00:33:32.730 --> 00:33:36.240 of goods are classified based on their essential character. 00:33:36.240 --> 00:33:40.620 NOWAK, MARYALICE While the new notes 15 says to classify these goods 00:33:40.620 --> 00:33:45.000 in section 11, provided that they retain the essential character 00:33:45.000 --> 00:33:46.770 of goods so that section. 00:33:47.650 --> 00:33:48.770 NOWAK, MARYALICE So would be essential. 00:33:48.770 --> 00:33:51.180 Characters are parted by their parent component. 00:33:51.180 --> 00:33:52.170 It's classified as apparel. 00:33:54.775 --> 00:33:58.069 NOWAK, MARYALICE Accordingly, all of this to say. 00:33:58.070 --> 00:34:01.200 NOWAK, MARYALICE That while this new Note 15 to section 11. 00:34:02.391 --> 00:34:05.550 NOWAK, MARYALICE Does clarify and confirm that items 00:34:05.550 --> 00:34:10.600 of smart apparel are classified pursuant to GRI 3B. 00:34:10.600 --> 00:34:12.870 So according to their essential character. 00:34:14.328 --> 00:34:17.480 NOWAK, MARYALICE It makes no changes to the legal principles 00:34:17.480 --> 00:34:20.340 that are used to classify these types of guards. 00:34:21.525 --> 00:34:24.310 NOWAK, MARYALICE And in fact, over the past several years, 00:34:24.310 --> 00:34:28.270 CBP has developed a consistent by the influence in 00:34:28.270 --> 00:34:32.200 which we determined that these essential character of smart apparel is, 00:34:32.200 --> 00:34:36.850 with very few exceptions, imparted by the documents themselves 00:34:36.850 --> 00:34:39.302 and not the electronic electronic components 00:34:39.303 --> 00:34:41.100 that are incorporated into them. 00:34:42.525 --> 00:34:45.100 NOWAK, MARYALICE So there's really nothing in this dude. 00:34:45.100 --> 00:34:46.870 No, that alters this approach. 00:34:49.775 --> 00:34:51.440 NOWAK, MARYALICE OK. 00:34:51.440 --> 00:34:54.100 NOWAK, MARYALICE And so for the purposes 00:34:54.100 --> 00:34:59.610 of classifying smarter apparel, there's no, you know, 15 also is really. 00:34:59.610 --> 00:35:01.970 NOWAK, MARYALICE Much Ado about nothing? 00:35:02.990 --> 00:35:05.640 We have been classifying these types of governments according 00:35:05.640 --> 00:35:08.240 to their essential character and we will continue to do so. 00:35:09.770 --> 00:35:12.320 NOWAK, MARYALICE And so did just finish up with this section. 00:35:12.320 --> 00:35:17.180 I thought I would quickly go over a couple of the rulings we've done 00:35:17.180 --> 00:35:18.590 on these types of goods. 00:35:19.700 --> 00:35:27.090 NOWAK, MARYALICE So first, here we have ruling N 272462 00:35:27.090 --> 00:35:28.950 which was issued back in 2016. 00:35:30.650 --> 00:35:33.490 NOWAK, MARYALICE And the subject of this request was described 00:35:33.490 --> 00:35:38.150 as a wearable technology kit, and it had two components. 00:35:38.150 --> 00:35:38.770 There was a fence. 00:35:38.770 --> 00:35:39.210 Pull over. 00:35:39.210 --> 00:35:41.630 NOWAK, MARYALICE And there was also a component 00:35:41.630 --> 00:35:44.140 that the company called a Data Module box, 00:35:45.210 --> 00:35:49.120 and this box housed a heart rate sensor and accelerometer 00:35:49.120 --> 00:35:50.300 and a couple of other items. 00:35:51.900 --> 00:35:54.860 NOWAK, MARYALICE And the way it works is that the user would download an app 00:35:54.860 --> 00:35:56.020 and pair it with the device. 00:35:56.020 --> 00:35:57.030 Most likely a smartphone. 00:35:59.150 --> 00:36:01.740 NOWAK, MARYALICE That would enable him to track heart rate, 00:36:01.740 --> 00:36:05.360 breathing rate, the number of steps he took and the number 00:36:05.360 --> 00:36:07.440 of calories burned while it was exercising. 00:36:08.500 --> 00:36:13.200 And I've included here some photos of a similar item from the company's website. 00:36:13.200 --> 00:36:17.000 This might not be the actual item that was the subject of the ruling, 00:36:17.000 --> 00:36:19.350 but it looks like it has pretty much the same features. 00:36:21.025 --> 00:36:25.830 NOWAK, MARYALICE And so you can see there was a Mens pullover, pretty basic. 00:36:25.830 --> 00:36:28.630 And then the data box could be attached to the government 00:36:28.630 --> 00:36:30.800 by some metal snaps on the front. 00:36:30.800 --> 00:36:33.490 And then the photo on the right shows what the government looked like 00:36:33.490 --> 00:36:35.120 without the data box snapped on. 00:36:36.775 --> 00:36:38.380 NOWAK, MARYALICE So what we had here was really 00:36:38.380 --> 00:36:42.220 a classic 3R IGRI three weeks situation. 00:36:42.220 --> 00:36:44.870 It was a good made up of different components 00:36:44.870 --> 00:36:48.740 that were presentation classifiable in different headings of the tariff. 00:36:49.780 --> 00:36:53.690 We haven't been pull over, that was classifiable in Chapter 61 00:36:53.690 --> 00:36:56.710 and the data box that would have gone into one 00:36:56.710 --> 00:37:00.980 of the technology chapters, maybe chapter 85 or Chapter 9, 00:37:00.980 --> 00:37:02.930 is a type of measuring instrument. 00:37:02.930 --> 00:37:05.750 NOWAK, MARYALICE And so the question here was 00:37:05.750 --> 00:37:08.860 which of these components in part of the goods essential character? 00:37:10.030 --> 00:37:12.180 NOWAK, MARYALICE And I discussed it with my counterparts 00:37:12.180 --> 00:37:15.600 who handle these other chapters, the tariffs, and we all took a look 00:37:15.600 --> 00:37:19.070 at the item and researched a couple of previous rulings 00:37:19.070 --> 00:37:23.380 that has similarities to what we had in front of us. 00:37:23.380 --> 00:37:26.260 And ultimately we determined that the essential character 00:37:26.260 --> 00:37:29.170 of this good was imparted by the Clover. 00:37:29.170 --> 00:37:32.260 The key idea being that it was entirely possible 00:37:32.260 --> 00:37:34.980 that someone would wear the government, say, just throw it 00:37:34.980 --> 00:37:38.840 on and go to the gym without necessarily stopping to snap 00:37:38.840 --> 00:37:40.530 on the data box and connect to the app. 00:37:40.530 --> 00:37:44.050 NOWAK, MARYALICE The government was completely usable at this way. 00:37:44.050 --> 00:37:46.000 NOWAK, MARYALICE Just as a government. 00:37:47.650 --> 00:37:51.150 NOWAK, MARYALICE So bottom line, in our opinion, it was reasonable 00:37:51.150 --> 00:37:56.040 to think the pullover could and would be used without the data box, 00:37:56.040 --> 00:37:59.430 but conversely it wasn't possible to use the data box 00:37:59.430 --> 00:38:03.740 without wearing the Clover, and so this item was classified 00:38:03.740 --> 00:38:06.570 as a Mens pullover in adding 6110. 00:38:07.968 --> 00:38:08.817 NOWAK, MARYALICE Hey. 00:38:10.770 --> 00:38:14.790 NOWAK, MARYALICE And then Next up on this is another ruling request 00:38:14.790 --> 00:38:19.480 we received that spurred a little bit different than the one we just saw. 00:38:19.480 --> 00:38:23.530 And this case there was sensor that incorporate rated a number 00:38:23.530 --> 00:38:27.410 of different electronic components and there were also a couple 00:38:27.410 --> 00:38:29.880 of types of wearing apparel that this component was going 00:38:29.880 --> 00:38:30.540 to be used with. 00:38:31.775 --> 00:38:33.820 NOWAK, MARYALICE There were multiple with shorts and also 00:38:33.820 --> 00:38:38.880 within snicker grades and so I worked with NIS, Antoinette Peek Williams 00:38:38.880 --> 00:38:41.230 on this ruling because she handles grimmenstein pants. 00:38:42.900 --> 00:38:45.700 NOWAK, MARYALICE And the company asked about a few different scenarios. 00:38:45.700 --> 00:38:46.810 As you can see here. 00:38:46.810 --> 00:38:49.210 They asked what the classification would be 00:38:49.210 --> 00:38:53.660 for the sensor was imported individually. 00:38:53.660 --> 00:38:58.230 Both the shorts and the Capris imported individually, 00:38:58.230 --> 00:39:01.490 and finally both the shorts and the capris. 00:39:01.490 --> 00:39:03.900 If they were reported with the sensor. 00:39:04.900 --> 00:39:07.490 NOWAK, MARYALICE And here are the next couple of slides. 00:39:07.490 --> 00:39:09.820 You can see how these items work. 00:39:09.820 --> 00:39:12.220 NOWAK, MARYALICE So first we have the shorts and the photo 00:39:12.220 --> 00:39:17.190 on the left looks like another pair of shorts, but then the second photo 00:39:17.190 --> 00:39:20.390 you could see that there was a slit in the back way stand 00:39:20.390 --> 00:39:24.070 where the sensor could be inserted and there was also some wiring 00:39:24.070 --> 00:39:26.450 in the waistband for the transmission of the data. 00:39:28.150 --> 00:39:30.710 NOWAK, MARYALICE They're just like the last ruling we looked at 00:39:30.710 --> 00:39:33.880 when the wearers Linda sensor into that opening. 00:39:33.880 --> 00:39:36.600 That's what enabled all of the management functions. 00:39:38.110 --> 00:39:41.320 NOWAK, MARYALICE And then next you can see the same idea 00:39:41.320 --> 00:39:42.830 with the women's capris. 00:39:42.830 --> 00:39:46.120 There was a slick in the back of the waistband for holding the sensor. 00:39:48.650 --> 00:39:52.200 NOWAK, MARYALICE And then finally, here are the classifications 00:39:52.200 --> 00:39:57.240 we ultimately came up with for each of the scenarios that were posed to us. 00:39:57.240 --> 00:40:01.410 First, the sensor, when imported individually, was classified 00:40:01.410 --> 00:40:03.800 by the NIST chat handles Chapter 9. 00:40:03.800 --> 00:40:10.230 The material schedule specifically in heading 9029 as measuring instrument. 00:40:10.230 --> 00:40:12.720 NOWAK, MARYALICE And reclassified the shorts and capris 00:40:12.720 --> 00:40:18.275 when imported separately in chapters 61 and 62 of the tariff as apparel. 00:40:19.375 --> 00:40:22.360 NOWAK, MARYALICE And finally, following the logic in the other ruling, 00:40:22.360 --> 00:40:26.950 we just looked at in cases where the sensor was imported together 00:40:26.950 --> 00:40:31.620 with one of the apparel items, either the men shorts or the women's increase. 00:40:31.620 --> 00:40:33.270 NOWAK, MARYALICE Tony and I determined 00:40:33.270 --> 00:40:37.530 that the essential character was imparted by the apparel again, 00:40:37.530 --> 00:40:40.910 for the same reason we just saw it would be reasonable 00:40:40.910 --> 00:40:44.150 for the user to to wear the shorts or the creed 00:40:44.150 --> 00:40:47.500 without necessarily using sensor. 00:40:47.500 --> 00:40:49.900 NOWAK, MARYALICE But the converse was not also true. 00:40:49.900 --> 00:40:52.870 Sensor needed something to hold it to the wearer's body 00:40:52.870 --> 00:40:55.380 so it could perform the measuring functions. 00:40:55.380 --> 00:40:58.760 So in that sense it was unusable without the apparel. 00:40:59.734 --> 00:41:01.550 NOWAK, MARYALICE Therefore, the essential character 00:41:01.550 --> 00:41:06.150 in each case was the apparel component and the apparel 00:41:06.150 --> 00:41:12.150 and sensor sets were classified in the apparel chapters pursuing two GRI 3B. 00:41:12.150 --> 00:41:13.470 NOWAK, MARYALICE OK. 00:41:14.650 --> 00:41:18.210 NOWAK, MARYALICE And that is all I have for today. 00:41:18.210 --> 00:41:21.100 Does anyone have any questions? 00:41:21.100 --> 00:41:27.410 And as I say that I'm going to open my chat box and see 00:41:27.410 --> 00:41:30.760 if anything came up during my presentation. 00:41:40.945 --> 00:41:43.590 NOWAK, MARYALICE And by webmasters can call my attention 00:41:43.590 --> 00:41:44.810 anything I might miss? 00:41:49.400 --> 00:41:52.640 NOWAK, MARYALICE Does the rib waistband have to be tight? 00:41:52.640 --> 00:41:58.500 I think if you go back and read the language, it says Ridgeway spend 00:41:58.500 --> 00:42:02.160 or I can't remember exactly how it's worded or another feature 00:42:02.160 --> 00:42:04.070 that provides tightening to the bottom of the government. 00:42:04.070 --> 00:42:06.830 NOWAK, MARYALICE So I'm not sure. 00:42:06.830 --> 00:42:12.950 I think Tony is a lesson objective term, but does it provide typing question? 00:42:15.820 --> 00:42:16.944 NOWAK, MARYALICE We'll cross the updated 00:42:16.945 --> 00:42:20.030 to show those rulings as revoked. 00:42:20.030 --> 00:42:22.775 Again, no, that's what I meant when I. 00:42:23.500 --> 00:42:26.950 NOWAK, MARYALICE Covered what was meant by reported by operation 00:42:26.950 --> 00:42:30.290 of law is that they will be considered revoked, 00:42:30.290 --> 00:42:33.140 basically because the law has changed since they were issue. 00:42:40.650 --> 00:42:43.050 NOWAK, MARYALICE Does the pocket have to be functional? 00:42:43.050 --> 00:42:46.380 What about a small coin pocket pulled over the waist? 00:42:46.380 --> 00:42:49.553 NOWAK, MARYALICE Well, I would consider a point proper 00:42:49.554 --> 00:42:50.610 to be functional. 00:42:50.610 --> 00:42:54.430 I'm not sure what does the pocket only have to be functional. 00:42:55.669 --> 00:42:58.069 NOWAK, MARYALICE And you can you can. 00:42:58.070 --> 00:43:02.180 You can unmute your mic and you can ask the question as well and then? 00:43:02.180 --> 00:43:04.640 NOWAK, MARYALICE That would be easier. 00:43:14.609 --> 00:43:16.790 NOWAK, MARYALICE I don't think there's anything, you know. 00:43:16.790 --> 00:43:18.990 You know the tariffs schedule, the explanatory notes 00:43:18.990 --> 00:43:22.250 that list out specific dimensions of profiles. 00:43:25.875 --> 00:43:27.300 NOWAK, MARYALICE Hello. 00:43:29.275 --> 00:43:32.430 NOWAK, MARYALICE What about ruins and speak to functional closure 00:43:32.430 --> 00:43:37.490 versus non functional, that is really outside the scope of my presentation, 00:43:37.490 --> 00:43:40.040 but it is my understanding that. 00:43:42.650 --> 00:43:45.610 NOWAK, MARYALICE Their need only be a full or partial opening 00:43:45.610 --> 00:43:48.500 in the neckline to be considered a shirt, 00:43:48.500 --> 00:43:53.610 and that there is no actual requirement for functional closure such as buttons. 00:44:01.852 --> 00:44:06.050 NOWAK, MARYALICE It sounds reminiscent of the clock bags 00:44:06.050 --> 00:44:08.060 and clock everything from the 80s. 00:44:08.060 --> 00:44:11.100 I really don't know what this means, but you can unmute your mic 00:44:11.100 --> 00:44:13.370 and and let me know. 00:44:13.370 --> 00:44:14.580 It sounds kind of fun. 00:44:22.650 --> 00:44:24.640 NOWAK, MARYALICE Let's see, I'll do the change device. 00:44:24.640 --> 00:44:29.730 NOWAK, MARYALICE Define anything a man wears on his upper body as a shirt. 00:44:31.336 --> 00:44:34.270 NOWAK, MARYALICE No, there are other headings in the tariff schedule 00:44:34.270 --> 00:44:37.650 that provide for men's upper body garments, for example. 00:44:37.650 --> 00:44:42.050 NOWAK, MARYALICE And adding 61 room 9 covers on T shirts 00:44:42.050 --> 00:44:47.750 and similar garments heading 6110 provides for sweaters, sweatshirts, 00:44:47.750 --> 00:44:49.990 vests, pullovers. 00:44:49.990 --> 00:44:55.000 NOWAK, MARYALICE Heading 6114 provides for other governments 00:44:55.000 --> 00:44:56.690 that are included. 00:44:56.690 --> 00:44:59.560 You know for one reason or another from all of the previous settings 00:44:59.560 --> 00:45:00.430 in that chapter. 00:45:00.430 --> 00:45:05.150 NOWAK, MARYALICE Also, depending 6211 for women Darwins in 00:45:05.150 --> 00:45:08.360 if garments are excluded from paying 6205, they would. 00:45:08.360 --> 00:45:12.400 NOWAK, MARYALICE Generally fall to pending 6211. 00:45:16.180 --> 00:45:18.860 NOWAK, MARYALICE Is the closure that clients still required. 00:45:18.860 --> 00:45:22.730 I think I just responded to them that is no. 00:45:24.525 --> 00:45:26.760 NOWAK, MARYALICE And when will the? 00:45:26.760 --> 00:45:28.310 Ohh here's the question of the day. 00:45:28.310 --> 00:45:30.560 The informed compliance publications. 00:45:30.560 --> 00:45:34.430 NOWAK, MARYALICE I know that I have updated my section, it is a. 00:45:34.430 --> 00:45:41.280 It is a huge undertaking to get all the NIST to update their sections from us. 00:45:41.280 --> 00:45:46.730 It goes for review and that takes some time and it is unfortunately 00:45:46.730 --> 00:45:48.530 out of our hands right now. 00:45:48.530 --> 00:45:51.940 The most updated information I received from headquarters 00:45:51.940 --> 00:45:53.060 that they are planning on. 00:45:53.060 --> 00:45:58.810 NOWAK, MARYALICE Republishing that ICP sometime this year, 00:45:58.810 --> 00:46:03.039 but beyond that I don't have any more concrete information on them so. 00:46:07.650 --> 00:46:11.620 NOWAK, MARYALICE See if you have a row church. 00:46:12.780 --> 00:46:15.730 NOWAK, MARYALICE If you have an overture no ribbing 00:46:15.730 --> 00:46:20.460 at the waist nor pockets, but only partial zipper, it sounds 00:46:20.460 --> 00:46:24.280 to me like that would be assured, but that is advisory. 00:46:24.280 --> 00:46:28.310 NOWAK, MARYALICE Not having seen the government or even a photo of it, and. 00:46:28.310 --> 00:46:34.380 NOWAK, MARYALICE You know, a refrain in our apparel branch 00:46:34.380 --> 00:46:37.560 at least it's that I know I don't rule it out samples. 00:46:37.560 --> 00:46:40.070 So if you really have a question on a particular environment, 00:46:40.070 --> 00:46:43.697 I would really recommend getting a binding ruling social 00:46:43.698 --> 00:46:45.160 what you have written. 00:46:45.160 --> 00:46:46.830 It sounds like it made me a shirt. 00:46:51.170 --> 00:46:52.530 NOWAK, MARYALICE And again, there are. 00:46:52.530 --> 00:46:53.280 There's no specific. 00:46:54.492 --> 00:46:57.820 NOWAK, MARYALICE Heading in Chapter 62 that provides for pullovers. 00:46:57.820 --> 00:46:59.940 So if any feature excluded that government. 00:46:59.940 --> 00:47:04.890 NOWAK, MARYALICE From paying 60 to apply the import, 00:47:04.890 --> 00:47:08.920 more than likely falling into heading 6211, which is other guns. 00:47:14.275 --> 00:47:16.630 NOWAK, MARYALICE Can we look at slide #27? 00:47:16.630 --> 00:47:18.440 You're just you're testing my. 00:47:19.320 --> 00:47:21.850 NOWAK, MARYALICE Teams prowess argue, so I'm gonna go to. 00:47:23.775 --> 00:47:25.890 NOWAK, MARYALICE Great view as I was trained to. 00:47:26.870 --> 00:47:28.210 Let's see. 00:47:31.525 --> 00:47:32.400 NOWAK, MARYALICE Here is. 00:47:32.400 --> 00:47:33.950 NOWAK, MARYALICE Slide 27. 00:47:33.950 --> 00:47:37.120 NOWAK, MARYALICE I'm not sure specifically what the question is, 00:47:37.120 --> 00:47:38.670 but you cannot your bike. 00:47:41.870 --> 00:47:44.420 NOWAK, MARYALICE In the meantime, the next question is 00:47:44.420 --> 00:47:46.750 what is shirt versus blouse? 00:47:46.750 --> 00:47:51.660 Again, I handle only men's garments and heading 6105 00:47:51.660 --> 00:47:55.800 and also 6205 cover only shirts. 00:47:55.800 --> 00:47:59.580 I know there have been some questions on women's blouses, 00:47:59.580 --> 00:48:04.220 but as I do not handle blouses, I am not equipped to answer that. 00:48:12.352 --> 00:48:13.900 NOWAK, MARYALICE Yeah, it's just functional. 00:48:13.900 --> 00:48:15.050 Opening the government has an opening. 00:48:15.050 --> 00:48:19.380 NOWAK, MARYALICE Like the Henley, but no means of closure. 00:48:19.380 --> 00:48:22.710 I know Butner, zipper with the speaker. 00:48:22.710 --> 00:48:25.810 Well, it would still have a functional. 00:48:25.810 --> 00:48:28.850 It still has an opening, and I there is. 00:48:28.850 --> 00:48:31.730 There is language in the explanatory note. 00:48:31.730 --> 00:48:34.090 I'm not sure precisely where it is. 00:48:34.090 --> 00:48:38.410 It might be in the general explanatory node to the, you know, 00:48:38.410 --> 00:48:41.450 the beginning of either chapter 61 or chapter 62. 00:48:41.450 --> 00:48:43.950 Or it might be at the heading level. 00:48:43.950 --> 00:48:45.900 But the language says something. 00:48:47.150 --> 00:48:49.180 NOWAK, MARYALICE It goes to the gender of the garands 00:48:49.180 --> 00:48:51.260 and it says something along the lines of. 00:48:51.260 --> 00:48:58.160 NOWAK, MARYALICE Openings that close or overlap leftover right 00:48:58.160 --> 00:49:02.530 are considered men's garments and right over left considered women's garments. 00:49:02.530 --> 00:49:09.390 And because of that language closes or overlaps, that is what has led us 00:49:09.390 --> 00:49:13.680 to to the understanding that a functional culture is not required. 00:49:23.150 --> 00:49:26.320 NOWAK, MARYALICE Man, how do you go back to take away 2 slide? 00:49:26.320 --> 00:49:28.910 Where is my take away to slide? 00:49:28.910 --> 00:49:31.300 Hopefully the person who wanted to see. 00:49:31.300 --> 00:49:37.510 NOWAK, MARYALICE On Slide 27, on was able to to get their clarification, 00:49:37.510 --> 00:49:42.600 if not is I said this webinar will be posted to our site probably 00:49:42.600 --> 00:49:47.270 in a few weeks, but let's see if I can help you with. 00:49:47.270 --> 00:49:48.970 NOWAK, MARYALICE Take away too. 00:49:50.610 --> 00:49:51.610 NOWAK, MARYALICE Right here. 00:49:52.318 --> 00:49:53.298 NOWAK, MARYALICE OK. 00:49:53.299 --> 00:49:56.079 NOWAK, MARYALICE Now let's take away 3, but we'll get there. 00:49:56.079 --> 00:49:58.400 NOWAK, MARYALICE How's this this cell? 00:50:02.430 --> 00:50:07.700 NOWAK, MARYALICE You cannot download the slides, but the entire presentation. 00:50:07.700 --> 00:50:12.620 This entire webinar today was recorded and it will be uploaded 00:50:12.620 --> 00:50:16.610 to our CP website in the next few weeks. 00:50:22.516 --> 00:50:24.200 NOWAK, MARYALICE Interior pocket. 00:50:24.200 --> 00:50:25.760 No, actually. 00:50:25.760 --> 00:50:28.470 OK, this question is garments with pockets below the waist. 00:50:28.470 --> 00:50:32.470 Does the entire pocket need to be below the waist or the majority of the pocket? 00:50:32.470 --> 00:50:35.220 NOWAK, MARYALICE The answer is actually 00:50:35.220 --> 00:50:38.640 and I think I'm pretty sure it's a headquarters, we're learning, 00:50:38.640 --> 00:50:40.270 but don't quote me on that. 00:50:40.270 --> 00:50:46.620 But there is a relatively recent ruling that came out that does discuss this 00:50:46.620 --> 00:50:50.940 and states that it any part of the pocket falls below the waist, 00:50:50.940 --> 00:50:53.740 it is considered a pocket below the waist. 00:50:53.740 --> 00:51:01.950 I don't have the number of that ruling here before me, but if you are, 00:51:01.950 --> 00:51:02.710 if you can email me. 00:51:02.710 --> 00:51:04.760 NOWAK, MARYALICE I can get it for you. 00:51:07.359 --> 00:51:10.170 NOWAK, MARYALICE So hopefully the person who asked 00:51:10.170 --> 00:51:15.280 for the take away #2 slide is finished and I am gonna go back. 00:51:15.280 --> 00:51:16.690 NOWAK, MARYALICE Uh. 00:51:18.023 --> 00:51:23.170 NOWAK, MARYALICE Here are two like content like contact information. 00:51:23.170 --> 00:51:25.750 NOWAK, MARYALICE If you can email it to me 00:51:25.750 --> 00:51:28.710 at the email address you see here, I will be happy 00:51:28.710 --> 00:51:29.900 to get that room number for you. 00:51:34.025 --> 00:51:35.890 NOWAK, MARYALICE Download the deck again. 00:51:35.890 --> 00:51:39.370 This is gonna be posted on to the CP website. 00:51:39.370 --> 00:51:40.580 The entire recording. 00:51:43.508 --> 00:51:45.990 NOWAK, MARYALICE Is it possible to have the slides downloaded? 00:51:45.990 --> 00:51:49.375 NOWAK, MARYALICE Again the. 00:51:50.313 --> 00:51:53.380 NOWAK, MARYALICE The entire recording is going to be uploaded 00:51:53.380 --> 00:51:58.520 to the CDC website and there are other past reported webinars 00:51:58.520 --> 00:52:01.420 and I am just gonna go back to the beginning. 00:52:01.420 --> 00:52:05.970 Part of the presentation because I did post a link to these webinars 00:52:05.970 --> 00:52:08.950 and then it's the link to see on your screen right now. 00:52:24.836 --> 00:52:26.200 NOWAK, MARYALICE OK. 00:52:26.200 --> 00:52:28.750 And Sandra, Wally, one of our. 00:52:39.525 --> 00:52:42.108 NOWAK, MARYALICE Does the smart government rule also apply 00:52:42.109 --> 00:52:43.580 to smart shoes? 00:52:43.580 --> 00:52:46.830 I do not handle footwear, but I would say to contact 00:52:46.830 --> 00:52:48.570 and I have Stacy Kalkines for that. 00:52:48.570 --> 00:52:52.300 NOWAK, MARYALICE And she'll be able to help you out. 00:52:58.525 --> 00:52:59.230 NOWAK, MARYALICE OK. 00:52:59.230 --> 00:53:03.050 Regards to the previous answer about the hands zippered shirt, 00:53:03.050 --> 00:53:04.430 no reading or pockets. 00:53:04.430 --> 00:53:07.100 Will it go under other garments? 00:53:07.100 --> 00:53:09.740 NOWAK, MARYALICE But not in other shirts excluded. 00:53:09.740 --> 00:53:12.670 If there is nothing to exclude it from 60 to 05. 00:53:13.775 --> 00:53:17.140 NOWAK, MARYALICE Then it remains in 6205, but again, 00:53:17.140 --> 00:53:22.330 I haven't seen the garment on, so I I hesitate to just classify blindly 00:53:22.330 --> 00:53:22.910 and ethical. 00:53:28.789 --> 00:53:29.704 NOWAK, MARYALICE Let's see. 00:53:31.540 --> 00:53:36.281 NOWAK, MARYALICE Does someone need to takeaways slide again? 00:53:38.805 --> 00:53:40.660 NOWAK, MARYALICE We didn't see it again, so I'll just. 00:53:41.650 --> 00:53:44.580 NOWAK, MARYALICE Go back to that one store. 00:53:44.580 --> 00:53:46.875 There you have that. 00:53:47.525 --> 00:53:50.874 NOWAK, MARYALICE And let's see. 00:53:55.150 --> 00:53:57.230 NOWAK, MARYALICE I don't know what you mean by that. 00:53:57.230 --> 00:53:59.620 We don't distribute the slides of previous webinars, 00:53:59.620 --> 00:54:01.946 but again all the recordings are available 00:54:01.947 --> 00:54:03.840 at that like I showed you earlier. 00:54:05.906 --> 00:54:09.890 NOWAK, MARYALICE I think that's all the questions I'm Sandra or anyone. 00:54:09.890 --> 00:54:11.750 You was there anything I missed? 00:54:13.275 --> 00:54:14.620 NOWAK, MARYALICE I think you got them all. 00:54:14.620 --> 00:54:17.200 There was one person who was who wanted to unmute themselves. 00:54:17.200 --> 00:54:18.710 If if you wanna mute, unmute yourself. 00:54:18.710 --> 00:54:20.520 You first have to raise your hand. 00:54:20.520 --> 00:54:23.470 When I see your name, I can give you the ability to unmute yourself. 00:54:25.086 --> 00:54:27.500 NOWAK, MARYALICE If you do want to raise your hand, it's at the top. 00:54:27.500 --> 00:54:29.900 It's the icon that says reactions. 00:54:29.900 --> 00:54:33.050 Hover over that and then you'll see the symbol of the hand 00:54:33.050 --> 00:54:33.840 and you can raise your hand. 00:54:39.400 --> 00:54:42.360 NOWAK, MARYALICE OK, let me I will give that person access. 00:54:42.360 --> 00:54:43.500 Uh, allow Mike. 00:54:43.500 --> 00:54:46.510 You should now be able to unmute yourself if you try clicking next 00:54:46.510 --> 00:54:48.770 to the button at the top for the microphone. 00:54:48.770 --> 00:54:49.340 I got it. 00:54:49.340 --> 00:54:51.510 Thank you so much, Mary Alice. 00:54:51.510 --> 00:54:53.760 Is this was a fantastic presentation. 00:54:53.760 --> 00:54:55.020 Let me just start off with that. 00:54:55.020 --> 00:54:56.625 NOWAK, MARYALICE Thank you. 00:54:57.570 --> 00:54:59.410 I do have a question again. 00:54:59.410 --> 00:55:05.040 I just it just for clarity purposes, OK, for so in for chapter 61. 00:55:05.040 --> 00:55:07.200 NOWAK, MARYALICE The neck opening so. 00:55:07.200 --> 00:55:10.530 NOWAK, MARYALICE So what we're saying is, 00:55:10.530 --> 00:55:13.840 even if there is like a Henley, so not not where to slice 00:55:13.840 --> 00:55:16.390 and then the garment just flaps over a little bit. 00:55:16.390 --> 00:55:20.900 NOWAK, MARYALICE That would be considered an opening regardless 00:55:20.900 --> 00:55:25.420 if there is a zipper or button or any other means of closure. 00:55:25.420 --> 00:55:29.760 So if it's just a cut and it just slightly and it just flips over, 00:55:29.760 --> 00:55:31.860 that's considered a neck opening, no? 00:55:31.860 --> 00:55:34.910 But I'll tell you I have hard time. 00:55:34.910 --> 00:55:38.870 Is there a portion that overlaps like this one side 00:55:38.870 --> 00:55:40.940 of that opening overlap the other? 00:55:42.050 --> 00:55:43.300 NOWAK, MARYALICE No, basically. 00:55:43.300 --> 00:55:47.240 Let's see, we just a straight cut in the in, in the center 00:55:47.240 --> 00:55:52.900 and then the neck opening just flaps over or it it's like a Mark Handley. 00:55:52.900 --> 00:55:55.270 Some I Hendley would have no one and I would really have 00:55:55.270 --> 00:55:58.670 to see that government live because I don't want to speak. 00:55:58.670 --> 00:56:02.980 And I think I mentioned a few minutes ago that there is an explanatory note 00:56:02.980 --> 00:56:04.910 and I don't know if it's. 00:56:04.910 --> 00:56:09.390 NOWAK, MARYALICE In the general explanatory notice, 61 or 62, 00:56:09.390 --> 00:56:13.630 we're talks about how to determine the gender of a government, 00:56:13.630 --> 00:56:18.420 and it says if there is an opening in the neckline that closes 00:56:18.420 --> 00:56:21.540 or overlaps leftover right? 00:56:21.540 --> 00:56:27.550 So from that I take, you know, I take away that the opening would have 00:56:27.550 --> 00:56:32.430 to close it regardless of whether it has a button or whatever the the term used 00:56:32.430 --> 00:56:34.700 in that explanatory note is overlap. 00:56:37.775 --> 00:56:39.150 NOWAK, MARYALICE So I would make maybe you know 00:56:39.150 --> 00:56:42.093 maybe if you wanna go back or, you know, send me an email. 00:56:42.102 --> 00:56:45.872 So I have your contact information and I'll find where in the explanatory note 00:56:45.900 --> 00:56:50.950 that is so we can we can take a look at you know the wording exactly 00:56:50.950 --> 00:56:52.120 what it says. 00:56:54.650 --> 00:56:56.890 NOWAK, MARYALICE And so it's very introduce saying an overlap. 00:56:56.890 --> 00:57:00.200 And so if there is no overlap and it just meets at the center, 00:57:00.200 --> 00:57:02.260 that's not considered an opening again. 00:57:02.260 --> 00:57:04.780 NOWAK, MARYALICE Really hard time it boosting that, yeah. 00:57:07.466 --> 00:57:08.019 NOWAK, MARYALICE All right. 00:57:08.020 --> 00:57:10.280 Thank you again, and I'll, I'll email you. 00:57:10.280 --> 00:57:10.625 Thank you. 00:57:10.625 --> 00:57:11.400 OK. 00:57:11.400 --> 00:57:12.230 Thanks. 00:57:12.230 --> 00:57:13.350 I saw one more question. 00:57:13.350 --> 00:57:13.690 OK. 00:57:13.690 --> 00:57:16.450 It does the smartest cells include metal that was added 00:57:16.450 --> 00:57:20.830 to the dope before spinning to prevent bacterial growth. 00:57:20.830 --> 00:57:24.550 I am not familiar with this. 00:57:25.453 --> 00:57:26.270 NOWAK, MARYALICE Can. 00:57:27.625 --> 00:57:29.400 NOWAK, MARYALICE Crystal can you maybe on your something? 00:57:31.328 --> 00:57:32.580 NOWAK, MARYALICE Tell me about this garment. 00:57:42.672 --> 00:57:43.950 NOWAK, MARYALICE So if you'd like to be unmuted 00:57:43.950 --> 00:57:45.540 if you could just raise your hand first. 00:57:48.844 --> 00:57:49.820 NOWAK, MARYALICE Great. 00:57:49.820 --> 00:57:50.630 Let me just. 00:57:50.630 --> 00:57:52.050 NOWAK, MARYALICE I don't see that. 00:58:14.602 --> 00:58:16.310 NOWAK, MARYALICE You should be able to unmute yourself now 00:58:16.310 --> 00:58:17.030 if you try Crystal. 00:58:24.070 --> 00:58:26.380 NOWAK, MARYALICE Go to the small microphone symbol at the top 00:58:26.380 --> 00:58:27.110 along the toolbar. 00:58:27.110 --> 00:58:29.680 NOWAK, MARYALICE And click on it so you can unmute yourself. 00:58:34.469 --> 00:58:35.090 NOWAK, MARYALICE There we go. 00:58:35.090 --> 00:58:36.270 Can you hear me? 00:58:36.270 --> 00:58:38.380 Yes, I can, alright. 00:58:38.380 --> 00:58:41.840 NOWAK, MARYALICE I was wondering because a few years ago 00:58:41.840 --> 00:58:46.830 we've had samples here in the lab that they were just blue jeans 00:58:46.830 --> 00:58:51.930 and the polyester in the in the jeans, they had to add it. 00:58:51.930 --> 00:58:52.300 Think. 00:58:52.300 --> 00:58:59.020 I think if I'm not mistaken and they wanted it classified as metalized. 00:58:59.020 --> 00:58:59.360 OK. 00:58:59.360 --> 00:58:59.690 Yeah. 00:58:59.690 --> 00:59:04.710 But it was added to the door before the policy that the dog is the name 00:59:04.710 --> 00:59:08.560 that the the polymer is called before it's turned into a fiber. 00:59:08.560 --> 00:59:11.060 NOWAK, MARYALICE And it changes the end use it 00:59:11.060 --> 00:59:13.700 actually prevents bacterial growth. 00:59:13.700 --> 00:59:17.960 The military developed that for socks too, where they add zinc 00:59:17.968 --> 00:59:22.100 into the polymer before it's turned into the fibers. 00:59:22.100 --> 00:59:25.070 I guess to prevent jungle rot in the sauce and stuff. 00:59:25.070 --> 00:59:27.430 NOWAK, MARYALICE That's smart apparel. 00:59:27.430 --> 00:59:31.270 NOWAK, MARYALICE It certainly changes the end cues, 00:59:31.270 --> 00:59:35.900 but you know it it gives you different attributes in the issues so. 00:59:35.900 --> 00:59:39.030 NOWAK, MARYALICE So does this ultimately be? 00:59:39.030 --> 00:59:41.125 It becomes blue jeans, right? 00:59:41.125 --> 00:59:42.320 Yes. 00:59:42.320 --> 00:59:45.100 Well, but does it change and use of blue jeans? 00:59:45.100 --> 00:59:47.520 Like, how do you blue jeans? 00:59:47.520 --> 00:59:51.600 NOWAK, MARYALICE But no, I I I suppose the only it 00:59:51.600 --> 00:59:54.800 just changes the the attributes like in the socks 00:59:54.800 --> 00:59:57.620 at the military developed it was really developed. 00:59:57.620 --> 01:00:02.970 So the soldiers when they had wet feet wouldn't get sick from it or something. 01:00:02.970 --> 01:00:04.110 Yeah, that is something. 01:00:04.110 --> 01:00:07.530 I mean, if you really wanted to classification and I would have to, 01:00:07.530 --> 01:00:08.360 you know, really take. 01:00:08.360 --> 01:00:10.610 I was just wondering if there was some kind of. 01:00:10.610 --> 01:00:14.770 NOWAK, MARYALICE But it's, I mean, smart apparel refers really to, 01:00:14.770 --> 01:00:17.740 you know, electronic components that you know. 01:00:17.740 --> 01:00:20.380 NOWAK, MARYALICE Your primary stuff like that, yeah. 01:00:26.150 --> 01:00:26.850 NOWAK, MARYALICE On. 01:00:28.525 --> 01:00:31.960 NOWAK, MARYALICE Someone wanted you to bring up slide 24 again for clarity. 01:00:31.960 --> 01:00:32.350 OK. 01:00:32.350 --> 01:00:32.940 Thank you, Sandra. 01:00:36.190 --> 01:00:37.690 NOWAK, MARYALICE There we go. 01:00:38.900 --> 01:00:40.124 NOWAK, MARYALICE OK. 01:01:13.921 --> 01:01:14.812 NOWAK, MARYALICE Anywhere else? 01:01:16.650 --> 01:01:18.960 NOWAK, MARYALICE Because it's like help you first. 01:01:29.977 --> 01:01:31.600 NOWAK, MARYALICE OK. 01:01:31.600 --> 01:01:34.564 Well, with that said, I'm gonna just briefly put up 01:01:34.565 --> 01:01:38.140 my contact information here and I do have to associate. 01:01:38.140 --> 01:01:40.270 So if I'm not, please reach out for one of them. 01:01:40.270 --> 01:01:43.650 We all work together as a team, so somebody should be able to. 01:01:43.650 --> 01:01:46.270 NOWAK, MARYALICE Quickly get you the answers you need. 01:01:46.270 --> 01:01:47.120 I'm good with that. 01:01:47.120 --> 01:01:50.220 I would like to thank everyone for joining me today. 01:01:50.220 --> 01:01:51.280 So have a good rest of your day.