WEBVTT

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>> CHRISSI GUTH: Good afternoon,

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everyone. I am Chrissi Guth

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with CBP's Office of Trade

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Relations. Today's webinar is

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on what is a men's T-shirt and

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what isn't a men's T-shirt.

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This webinar is a part of the

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NCSD 2023 Webinar Series.

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Please be mindful that you will

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be on mute during the

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presentation. Therefore, we ask

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that you please submit any

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questions you have in the chat

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feature.

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Now I would like to pass it

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over to National Import

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Specialist Maryalice Nowak.

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>> MARYALICE NOWAK: Thank you,

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Chrissi. And hello, everyone.

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Welcome to today's webinar on

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what is and isn't a men's

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T-shirt. And thank you for your

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patience as we sorted out a few

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technical issues on our end. As

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Chrissi said, my name is

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Maryalice Nowak, and I am the

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national Import Specialist for

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most of men's apparel, although

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with some exceptions, such as

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outer wear, sleep wear, swim

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wear, a few other things.

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Before I get started on today's

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topic, I'd like to call your

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attention to CBP's Mission

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Statement which you can see on

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this slide. And also important

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is the mission of the Office of

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Trade, which includes

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facilitating legitimate trade.

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That is a big part of what we do

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at the National Commodity

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Specialist division, where we're

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writing rulings or responding to

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questions from the trade, or

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presenting webinars. So I'd

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like to thank you all for

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joining me today and helping me

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do my job.

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Next, I would like to just

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briefly go over this disclaimer.

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Those of you who have joined us

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for previous webinars will have

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seen this already, but for those

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who haven't, what this slide

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basically says is that the

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information I'll be covering

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today is for training purposes,

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but it is advisory only and it

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shouldn't be considered binding.

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Also, the photos I've included

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in this presentation have been

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obtained legally and are being

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used legally, and I'll be using

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these photos only to illustrate

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the various points that I'll be

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talking about. So by showing

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you a photo of a garment, it

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does not mean that I'm

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officially providing a

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classification of that garment.

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Anyone who has requested rulings

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on apparel knows that except in

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rare instances, we always need a

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sample in order to issue a

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ruling, and that's because a lot

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of the things we need to know

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about a garment aren't

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necessarily apparent from the

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description you give us or even

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a photo. And speaking of

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binding rulings, I have included

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on this next slide, the link for

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submitting an electronic ruling

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on your merchandise. And I'll

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give you a second to jot it

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down. While you do that, I will

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just remind you that it is

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possible to submit an eRuling

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request even if you need to send

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in a sample. What happens is

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that once you click that submit

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button, you'll get an E-mail

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from us with instructions on how

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and where to send that sample.

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So it is a fairly easy process.

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And then finally, as Chrissi

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mentioned, if anyone has

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questions while I'm going

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through my presentation, please

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just go ahead and type them into

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the chat box. I won't be taking

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questions during the

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presentation, but this way we

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can be sure to circle back to

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them at the end. Okay?

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So with that, I am going to get

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started.

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So when I was thinking about

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possible topics for this year's

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webinar, I naturally gravitated

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toward T-shirts of heading 6109

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and also pullovers of 6110, and

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that's because those are the

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headings I handle that seem to

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generate the most questions from

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the trade. And then when the

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apparel, footwear and textile

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center canvassed the trade for

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what topics you wanted to see

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presented, quite a few questions

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came back that had to do with

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T-shirts. So apparently my

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instincts were right on the

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money here.

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Now, I did present a webinar on

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T-shirts, along with my

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colleague, Antoinette Pete

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Williams, who handles women's

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T-shirts, back in 2017, but that

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was a long time ago. I can't

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believe it's been six years

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already, so -- but it does seem

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to be a topic that bears, well,

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maybe not repeating, but I think

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it's probably worth some

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revisiting and reinforcement and

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maybe a little updating.

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Especially since there's

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probably been some turnover at

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your companies, and maybe some

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newer employees aren't as

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familiar or comfortable with

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this topic as they'd like to be.

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And so you can see here on

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these next two slides the parts

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of the tariff schedule that I'll

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be talking about and these

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particular experts are for

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garments of man-made fiber, but

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there are corresponding

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provisions for cotton. So I'm

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going to be covering T-shirts.

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Garments we call similar to a

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T-shirt, which are classifiable

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within the other subheading that

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I've highlighted on the bottom

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of this slide, and then finally

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some garments that are excluded

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from heading 6109 entirely, and

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that usually end up being

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classified as pullovers in

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heading 6110, as you can see

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here.

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So like I said, I do seem to

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get a lot of questions about how

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to classify T-shirts, and these

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questions usually have to do

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with the different features on a

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garment that might move it out

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of a T-shirt classification and

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into either a different part of

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heading 6109 or out of 6109 and

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into 6110. But what I'd really

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like to do today is take a step

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back from these lists of

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features that we've developed

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over the years and talk about

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the history and the reasoning

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behind our methodology for

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classifying these kinds of

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garments. And then I'll get to

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those lists of features, I

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promise. But I do want to start

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with the reasons these garments

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have come to be classified the

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way they are, because hopefully

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that will help you to understand

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the proper approach for

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classifying the garments you

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have. Okay?

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So to do this, I would first

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like to share with you some

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definitions of the term

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"T-shirt" that should help to

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shed some light on this. And

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the first thing you might notice

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when you're trying to figure out

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if the garment you have in front

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of you is, in fact, a T-shirt,

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is that the harmonized tariff

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schedule does not actually

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define T-shirt, because what fun

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would that be, right? But

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absent a definition of T-shirt

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in the tariff schedule, the next

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place to go to look is the

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explanatory notes, which, as you

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might recall, the explanatory

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notes are not legally binding in

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the way that the tariff schedule

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is. But they are helpful in

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that they constitute the

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official interpretation of the

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tariff schedule at the

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international level.

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So here on this slide is what

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the explanatory notes tell us

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about T-shirts. And I'm not

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going to be reading every slide

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today word for word, but I think

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it's important to read this one.

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So on the explanatory notes

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define T-shirts as lightweight,

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knitted or crocheted garments of

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the vest type, of cotton or

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manmade fiber, not napped nor of

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pile or Terry fabric, in one or

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more colors, with or without

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pockets, with long or short,

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close-fitting sleeves, without

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buttons or other fastenings,

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without collar, without opening

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in the neck line, having a

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close-fitting or a lower

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neckline, and some types of

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necklines are listed there.

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These garments may have

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decoration other than lace, in

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the form of advertising,

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pictures, inscriptions or words,

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obtained by printing, few other

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processes. And the bottom of

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these garments is usually

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hemmed.

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The note goes on to say that in

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accordance with Chapter Note 5,

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and that's of the tariff

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schedule, garments with a

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drawstring, ribbed waistband or

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other means of tightening at the

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bottom are excluded from this

00:08:21.999 --> 00:08:23.976 position:20%
heading.

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Now, in addition to the

00:08:25.250 --> 00:08:28.976
explanatory notes, another good

00:08:29.000 --> 00:08:30.143
resource you have available to

00:08:30.167 --> 00:08:33.852
you is CBP's Informed Compliance

00:08:33.876 --> 00:08:36.975 position:20%
Publication, or ICP, that's

00:08:36.999 --> 00:08:40.518
entitled classification: Apparel

00:08:40.542 --> 00:08:43.852
terminology under the harmonized

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schedule of the United States,

00:08:45.334 --> 00:08:46.852
and you can find that at our Web

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site, and that's www.cbp.gov.

00:08:51.792 --> 00:08:54.351
And please bear with me as I

00:08:54.375 --> 00:08:56.143
read one more slide. Because

00:08:56.167 --> 00:08:57.476
this is pretty understanding of

00:08:57.500 --> 00:08:59.351
how we think of T-shirts. So

00:08:59.375 --> 00:09:01.852
this ICP says the T-shirts are

00:09:01.876 --> 00:09:03.351 position:20%
underwear style garments

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constructed from lightweight,

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plain jersey or interlock knit

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fabric and it further tells us

00:09:09.626 --> 00:09:11.226
not over 200 grams per square

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meter, with short, close-fitting

00:09:12.999 --> 00:09:13.976 position:20%
hemmed sleeves and a hemmed

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bottom. It goes on to say that

00:09:15.999 --> 00:09:17.852
T-shirts have close-fitting or

00:09:17.876 --> 00:09:19.310
lower neck lines. Again, some

00:09:19.334 --> 00:09:20.852
types of necklines are listed

00:09:20.876 --> 00:09:22.476 position:20%
here. Buttons and other

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fastenings, opening in the

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neckline, collars, embroidery,

00:09:27.626 --> 00:09:28.810
and other features inconsistent

00:09:28.834 --> 00:09:30.975
with an underwear-style garment

00:09:30.999 --> 00:09:32.351
are not present. And again, it

00:09:32.375 --> 00:09:33.393
mentions the T-shirts do not

00:09:33.417 --> 00:09:36.435
have a drawstring, ribbed knit

00:09:36.459 --> 00:09:38.435 position:20%
waistband or other means of

00:09:38.459 --> 00:09:41.935
tightening at the bottom. Okay?

00:09:41.959 --> 00:09:43.810
And I think that by comparing

00:09:43.834 --> 00:09:45.143
and contrasting what these two

00:09:45.167 --> 00:09:47.560
documents, the explanatory notes

00:09:47.584 --> 00:09:49.975
and this ICP have to say about

00:09:49.999 --> 00:09:52.185
T-shirts, this can go a long way

00:09:52.209 --> 00:09:53.643
toward helping you understand

00:09:53.667 --> 00:09:57.226
why we classify T-shirts and

00:09:57.250 --> 00:09:58.975
T-shirt-type garments the way we

00:09:58.999 --> 00:10:01.476
do, and also how we treat the

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different kinds of features that

00:10:02.999 --> 00:10:04.768
we might see on these types of

00:10:04.792 --> 00:10:08.351 position:20%
garments.

00:10:08.375 --> 00:10:09.852
So the first thing I'd like to

00:10:09.876 --> 00:10:11.727 position:20%
point out about these two

00:10:11.751 --> 00:10:13.059 position:20%
documents is that the

00:10:13.083 --> 00:10:14.101 position:20%
explanatory notes say that

00:10:14.125 --> 00:10:15.935
T-shirts are garments of the

00:10:15.959 --> 00:10:18.852
vest type, while the ICP says

00:10:18.876 --> 00:10:20.435
that they are underwear style

00:10:20.459 --> 00:10:22.101 position:20%
garments.

00:10:22.125 --> 00:10:23.810
And these two statements might

00:10:23.834 --> 00:10:26.435
look to be contradictory on the

00:10:26.459 --> 00:10:28.351 position:20%
surface, but I'm going to

00:10:28.375 --> 00:10:29.727
explain not only why they're

00:10:29.751 --> 00:10:31.351
really not contradictory, but

00:10:31.375 --> 00:10:34.393
also why this is probably the

00:10:34.417 --> 00:10:36.602 position:20%
most important point in

00:10:36.626 --> 00:10:37.476
understanding how to classify

00:10:37.500 --> 00:10:39.975 position:20%
these garments.

00:10:39.999 --> 00:10:41.268 position:20%
So the key here is

00:10:41.292 --> 00:10:42.894 position:20%
understanding what the

00:10:42.918 --> 00:10:44.810
explanatory notes mean when they

00:10:44.834 --> 00:10:46.602
say the T-shirts are garments of

00:10:46.626 --> 00:10:48.643
the vest type. Because when you

00:10:48.667 --> 00:10:51.351
hear the word "vest" you might

00:10:51.375 --> 00:10:52.976
think of a sleeveless sweater

00:10:53.000 --> 00:10:55.018
type of garment. But that's not

00:10:55.042 --> 00:10:57.393
what this note is talking about.

00:10:57.417 --> 00:10:59.059 position:20%
And there is a headquarters

00:10:59.083 --> 00:11:05.143
ruling. It's HQ-950855, that

00:11:05.167 --> 00:11:07.476
dates back to 1992, and this

00:11:07.500 --> 00:11:11.226
ruling talks about how the word

00:11:11.250 --> 00:11:12.935
"vest" is really a British term

00:11:12.959 --> 00:11:14.310
that's used to mean an underwear

00:11:14.334 --> 00:11:17.018
type garment. Like I said, the

00:11:17.042 --> 00:11:19.226
explanatory notes constitute the

00:11:19.250 --> 00:11:21.018
official interpretation of the

00:11:21.042 --> 00:11:22.310 position:20%
tariff schedule at the

00:11:22.334 --> 00:11:23.975 position:20%
international level. So it

00:11:23.999 --> 00:11:25.975
helps to keep in mind that the

00:11:25.999 --> 00:11:27.894 position:20%
terminology you see there

00:11:27.918 --> 00:11:29.185 position:20%
reflects the international

00:11:29.209 --> 00:11:31.727
meaning of certain words, which

00:11:31.751 --> 00:11:32.975
aren't always the same as what

00:11:32.999 --> 00:11:34.101
those words mean in the United

00:11:34.125 --> 00:11:36.894 position:20%
States.

00:11:36.918 --> 00:11:38.935 position:20%
And as further confirmation

00:11:38.959 --> 00:11:41.975 position:20%
that this is what the

00:11:41.999 --> 00:11:42.852
explanatory notes are talking

00:11:42.876 --> 00:11:44.768
about when they say "vest," if

00:11:44.792 --> 00:11:47.185 position:20%
you look at Fairchild's

00:11:47.209 --> 00:11:48.643
Dictionary of Fashion, you'll

00:11:48.667 --> 00:11:50.643
see a number of cross-references

00:11:50.667 --> 00:11:52.101 position:20%
in the entries for vests,

00:11:52.125 --> 00:11:53.518
undergarments and T-shirts. And

00:11:53.542 --> 00:11:54.975
I've put some of these up on

00:11:54.999 --> 00:11:59.685
this slide. So what it comes

00:11:59.709 --> 00:12:00.975 position:20%
down to here, and this is

00:12:00.999 --> 00:12:03.476
important, is that true T-shirts

00:12:03.500 --> 00:12:06.602
are underwear-type garments.

00:12:06.626 --> 00:12:07.975
And as you'll see a little later

00:12:07.999 --> 00:12:10.143
on when we take a look at some

00:12:10.167 --> 00:12:10.975
of the different features you

00:12:10.999 --> 00:12:12.602 position:20%
might see on some of these

00:12:12.626 --> 00:12:14.435 position:20%
garments, the underlying

00:12:14.459 --> 00:12:16.727
consideration is always, always,

00:12:16.751 --> 00:12:19.975
always whether or not a given

00:12:19.999 --> 00:12:22.351 position:20%
feature detracts from the

00:12:22.375 --> 00:12:24.476
garment's basic character and

00:12:24.500 --> 00:12:26.768
appearance as underwear. If you

00:12:26.792 --> 00:12:28.768
take nothing else away from this

00:12:28.792 --> 00:12:30.351 position:20%
webinar today, please just

00:12:30.375 --> 00:12:32.894 position:20%
remember that, because it's

00:12:32.918 --> 00:12:33.768 position:20%
pretty much the basis of

00:12:33.792 --> 00:12:34.727 position:20%
everything I'll be talking

00:12:34.751 --> 00:12:39.727 position:20%
about. Okay?

00:12:39.751 --> 00:12:41.975
So this idea of T-shirts being

00:12:41.999 --> 00:12:44.560
underwear-type garments also

00:12:44.584 --> 00:12:47.351
pretty much explains the next

00:12:47.375 --> 00:12:48.393 position:20%
what might look like a

00:12:48.417 --> 00:12:49.975 position:20%
contradiction between the

00:12:49.999 --> 00:12:52.727
explanatory notes and the ICP.

00:12:52.751 --> 00:12:54.268
Which is that the explanatory

00:12:54.292 --> 00:12:58.393
notes say the T-shirts must be

00:12:58.417 --> 00:13:00.768
knitted or crocheted, but not

00:13:00.792 --> 00:13:03.975
napped, nor of pile or terry

00:13:03.999 --> 00:13:05.518
fabric. But the ICP takes this

00:13:05.542 --> 00:13:07.143
a step further and says they

00:13:07.167 --> 00:13:10.059
must be made of plain jersey or

00:13:10.083 --> 00:13:12.810 position:20%
interlock knit fabric.

00:13:12.834 --> 00:13:15.975
Now, a good explanation of this

00:13:15.999 --> 00:13:17.351 position:20%
can also be found in that

00:13:17.375 --> 00:13:18.393 position:20%
headquarters ruling I just

00:13:18.417 --> 00:13:21.143
mentioned, 950855, which ruled

00:13:21.167 --> 00:13:23.101
that the subject garment was not

00:13:23.125 --> 00:13:25.810
a T-shirt because the fabric it

00:13:25.834 --> 00:13:27.935
was made of was not the type of

00:13:27.959 --> 00:13:30.518
fabric that would be used for

00:13:30.542 --> 00:13:32.310
underwear. Specifically, the

00:13:32.334 --> 00:13:34.226 position:20%
garment was constructed of

00:13:34.250 --> 00:13:37.226 position:20%
open-work mesh knit fabric.

00:13:37.250 --> 00:13:38.685
And the ruling goes on to say

00:13:38.709 --> 00:13:41.810 position:20%
that the trade regards only

00:13:41.834 --> 00:13:45.310
light weight, plain jersey or

00:13:45.334 --> 00:13:46.435 position:20%
interlock fabric as being

00:13:46.459 --> 00:13:47.975 position:20%
consistent with underwear.

00:13:47.999 --> 00:13:49.185 position:20%
Okay?

00:13:49.209 --> 00:13:50.975 position:20%
So this ruling is important

00:13:50.999 --> 00:13:53.101
because it serves as our legal

00:13:53.125 --> 00:13:56.059 position:20%
basis for classifying only

00:13:56.083 --> 00:13:57.975
garments constructed of these

00:13:57.999 --> 00:14:01.310 position:20%
fabrics as T-shirts. And I

00:14:01.334 --> 00:14:02.975
really want to make sure this is

00:14:02.999 --> 00:14:03.810 position:20%
clear because one of the

00:14:03.834 --> 00:14:04.975
questions we receive from the

00:14:04.999 --> 00:14:07.975 position:20%
trade had to do with, quote

00:14:07.999 --> 00:14:09.476
unquote, T-shirts that are made

00:14:09.500 --> 00:14:12.310
of slug knit fabric. And just

00:14:12.334 --> 00:14:13.975
so everyone understands what I'm

00:14:13.999 --> 00:14:16.268
talking about, I've included a

00:14:16.292 --> 00:14:23.476
photo of slub knit fabric here.

00:14:23.500 --> 00:14:25.101
So this type of fabric is knit

00:14:25.125 --> 00:14:27.018
with I'll call them little lumps

00:14:27.042 --> 00:14:28.976
or imperfections. They also

00:14:29.000 --> 00:14:30.685
look like knots, and they add

00:14:30.709 --> 00:14:31.975 position:20%
some visual interest to the

00:14:31.999 --> 00:14:33.476
garment and they also create a

00:14:33.500 --> 00:14:34.560
texture on the fabric that you

00:14:34.584 --> 00:14:35.935
can feel if you run your hand

00:14:35.959 --> 00:14:39.268 position:20%
along the surface.

00:14:39.292 --> 00:14:41.310
Now, it still might be jersey

00:14:41.334 --> 00:14:42.560
fabric, but not necessarily. It

00:14:42.584 --> 00:14:43.518
might be a different kind of

00:14:43.542 --> 00:14:47.560
knit. But is a garment made

00:14:47.584 --> 00:14:50.393
of slub knit fabric a T-shirt?

00:14:50.417 --> 00:14:53.143
Why or why not? And if you'd

00:14:53.167 --> 00:14:54.975
like, you can type your answer

00:14:54.999 --> 00:15:01.393
into the chat box. Perfect. I

00:15:01.417 --> 00:15:02.560
am seeing a lot of no answers

00:15:02.584 --> 00:15:05.518
come in, just as I had hoped,

00:15:05.542 --> 00:15:07.935
and that is right. A, quote

00:15:07.959 --> 00:15:10.602
unquote, T-shirt, so that's made

00:15:10.626 --> 00:15:15.101
from slub jersey fabric is not

00:15:15.125 --> 00:15:16.727
classifiable as a T-shirt for

00:15:16.751 --> 00:15:17.975
tariff purposes because T-shirts

00:15:17.999 --> 00:15:19.518
must be constructed of either

00:15:19.542 --> 00:15:21.852
plain jersey or plain interlock

00:15:21.876 --> 00:15:23.768
knit fabric. And again, that is

00:15:23.792 --> 00:15:25.852
per that headquarters ruling I

00:15:25.876 --> 00:15:29.602 position:20%
just talked about. Okay?

00:15:29.626 --> 00:15:31.685
And while I'm on the topic of

00:15:31.709 --> 00:15:32.852 position:20%
the type of fabric that's

00:15:32.876 --> 00:15:35.226
acceptable for T-shirts, some of

00:15:35.250 --> 00:15:36.476
you may have noticed that this

00:15:36.500 --> 00:15:38.975
ruling we've been looking at

00:15:38.999 --> 00:15:40.976
also mentions that the fabric of

00:15:41.000 --> 00:15:43.518
the garment must be lightweight.

00:15:43.542 --> 00:15:44.975
And both the explanatory notes

00:15:44.999 --> 00:15:46.810
and the ICP say this. But you

00:15:46.834 --> 00:15:49.226
might ask yourself, what exactly

00:15:49.250 --> 00:15:52.975 position:20%
is considered lightweight?

00:15:52.999 --> 00:15:55.476
Well, never fear. We have a

00:15:55.500 --> 00:15:57.643
ruling that talks about that,

00:15:57.667 --> 00:15:58.975 position:20%
too. This is headquarters

00:15:58.999 --> 00:16:03.018
ruling 951116, and it's also

00:16:03.042 --> 00:16:04.852
from 1992, and it talks about

00:16:04.876 --> 00:16:07.975 position:20%
this idea of heavier-weight

00:16:07.999 --> 00:16:09.143
T-shirts, particularly T-shirts

00:16:09.167 --> 00:16:12.268
that are used as conventional

00:16:12.292 --> 00:16:13.894
attire, as opposed to strictly

00:16:13.918 --> 00:16:15.768
underwear. And these types of

00:16:15.792 --> 00:16:17.935
garments were becoming a fashion

00:16:17.959 --> 00:16:19.602
staple pretty much at the time

00:16:19.626 --> 00:16:24.894
this ruling was written. So as

00:16:24.918 --> 00:16:25.518
far as an acceptable weight on

00:16:25.542 --> 00:16:27.685
these newer garments, the ruling

00:16:27.709 --> 00:16:30.976
stated, these outerwear T-shirts

00:16:31.000 --> 00:16:32.685
generally vary in weight from

00:16:32.709 --> 00:16:34.476 position:20%
160 grams to 180 grams per

00:16:34.500 --> 00:16:35.975
square meter, with some garments

00:16:35.999 --> 00:16:37.768
approaching 200 grams per square

00:16:37.792 --> 00:16:41.143 position:20%
meter.

00:16:41.167 --> 00:16:42.518
And the ruling goes on to say

00:16:42.542 --> 00:16:44.101
that this range of acceptable

00:16:44.125 --> 00:16:45.975 position:20%
weights for T-shirts was

00:16:45.999 --> 00:16:47.975
consistent with trade practice,

00:16:47.999 --> 00:16:49.059
and it actually mentions a few

00:16:49.083 --> 00:16:51.975 position:20%
companies by name that were

00:16:51.999 --> 00:16:53.894
advertising heavier T-shirts as

00:16:53.918 --> 00:16:55.852
weighing up to 200 grams per

00:16:55.876 --> 00:16:58.351 position:20%
square meter.

00:16:58.375 --> 00:16:59.810 position:20%
So customs at the time

00:16:59.834 --> 00:17:03.852
recognized that some garments

00:17:03.876 --> 00:17:05.351
that were commercially known as

00:17:05.375 --> 00:17:06.975
T-shirts could weigh up to 200

00:17:06.999 --> 00:17:09.018
grams per square meter while

00:17:09.042 --> 00:17:10.975
still being consistent with the

00:17:10.999 --> 00:17:12.852 position:20%
definition of T-shirts as

00:17:12.876 --> 00:17:15.975 position:20%
lightweight garments.

00:17:15.999 --> 00:17:19.351
And so way back in 1992, you

00:17:19.375 --> 00:17:20.310
can see that headquarters did

00:17:20.334 --> 00:17:22.226
give us an upper limit for how

00:17:22.250 --> 00:17:23.602
heavy a garment could be and

00:17:23.626 --> 00:17:25.975
still be considered a T-shirt.

00:17:25.999 --> 00:17:27.018 position:20%
And this ruling is still in

00:17:27.042 --> 00:17:28.975
effect today. So this is our

00:17:28.999 --> 00:17:32.768
legal basis for using 200 grams

00:17:32.792 --> 00:17:34.810
per square meter as the maximum

00:17:34.834 --> 00:17:37.894 position:20%
weight for a T-shirt.

00:17:37.918 --> 00:17:41.351 position:20%
So to recap, T-shirts, by

00:17:41.375 --> 00:17:43.185
definition, are underwear-type

00:17:43.209 --> 00:17:45.435 position:20%
garments, and they must be

00:17:45.459 --> 00:17:47.143 position:20%
constructed of lightweight,

00:17:47.167 --> 00:17:49.560 position:20%
plain jersey, or interlock

00:17:49.584 --> 00:17:50.476
fabric. And we have rulings

00:17:50.500 --> 00:17:52.768
that explain the reasoning for

00:17:52.792 --> 00:17:57.810 position:20%
this. Okay?

00:17:57.834 --> 00:17:58.975 position:20%
And then, just to finish up

00:17:58.999 --> 00:18:00.975
this section on what might look

00:18:00.999 --> 00:18:03.226
like contradictions between the

00:18:03.250 --> 00:18:05.810
explanatory notes and the ICP,

00:18:05.834 --> 00:18:06.975
some of you may have noticed

00:18:06.999 --> 00:18:08.976
that the explanatory notes say

00:18:09.000 --> 00:18:11.476
that T-shirts may have either

00:18:11.500 --> 00:18:14.643 position:20%
long or short close-fitting

00:18:14.667 --> 00:18:16.560
sleeves. But the ICP says that

00:18:16.584 --> 00:18:18.975
T-shirts have short sleeves. So

00:18:18.999 --> 00:18:21.975 position:20%
what's up with this? Well,

00:18:21.999 --> 00:18:22.976 position:20%
what's up with this is that

00:18:23.000 --> 00:18:24.975
remember I mentioned earlier,

00:18:24.999 --> 00:18:26.727
the explanatory notes constitute

00:18:26.751 --> 00:18:29.226
the official interpretation of

00:18:29.250 --> 00:18:31.059
the harmonized tariff schedule

00:18:31.083 --> 00:18:33.975
at the international level. And

00:18:33.999 --> 00:18:35.435 position:20%
at the international level,

00:18:35.459 --> 00:18:37.393
T-shirt-type garments with long

00:18:37.417 --> 00:18:40.643 position:20%
sleeves are classifiable in

00:18:40.667 --> 00:18:46.393
heading 6109. But as far as the

00:18:46.417 --> 00:18:47.976
harmonized tariff schedule of

00:18:48.000 --> 00:18:48.685 position:20%
the United States, the

00:18:48.709 --> 00:18:49.852
difference between classifying a

00:18:49.876 --> 00:18:52.393 position:20%
garment as a T-shirt or as

00:18:52.417 --> 00:18:54.268 position:20%
similar to a T-shirt in the

00:18:54.292 --> 00:18:57.476
other provision of heading 6109,

00:18:57.500 --> 00:19:01.393
that arises at the ten-digit

00:19:01.417 --> 00:19:02.435 position:20%
statistical level, which is

00:19:02.459 --> 00:19:05.018 position:20%
strictly a U.S. breakout.

00:19:05.042 --> 00:19:07.975
And so when U.S. Customs was

00:19:07.999 --> 00:19:09.602 position:20%
deciding what features of a

00:19:09.626 --> 00:19:11.351
garment to include and exclude

00:19:11.375 --> 00:19:12.768
as far as T-shirt classification

00:19:12.792 --> 00:19:15.101
was concerned, they took the

00:19:15.125 --> 00:19:17.935
stance that long sleeves made a

00:19:17.959 --> 00:19:19.768
garment similar to a T-shirt

00:19:19.792 --> 00:19:23.518
rather than a true T-shirt at

00:19:23.542 --> 00:19:25.518
the ten-digit level, and that

00:19:25.542 --> 00:19:27.852
these types of garments should

00:19:27.876 --> 00:19:28.976
be classified within the other

00:19:29.000 --> 00:19:30.059 position:20%
provision as similar to a

00:19:30.083 --> 00:19:33.310 position:20%
T-shirt.

00:19:33.334 --> 00:19:36.518 position:20%
And so here, again, is that

00:19:36.542 --> 00:19:37.975
page of the tariff schedule I

00:19:37.999 --> 00:19:40.185 position:20%
showed you earlier. So

00:19:40.209 --> 00:19:42.685
long-sleeve garments would be

00:19:42.709 --> 00:19:43.894 position:20%
classified in that other

00:19:43.918 --> 00:19:46.268
provision that you see at the

00:19:46.292 --> 00:19:50.935 position:20%
bottom.

00:19:50.959 --> 00:19:52.226
So now that we've gone through

00:19:52.250 --> 00:19:55.018
these comparisons and contrasts,

00:19:55.042 --> 00:19:56.935
next I'd like to shift gears a

00:19:56.959 --> 00:19:58.727 position:20%
little bit and move on to a

00:19:58.751 --> 00:20:00.976
brief discussion of how T-shirts

00:20:01.000 --> 00:20:03.685 position:20%
are constructed.

00:20:03.709 --> 00:20:05.810 position:20%
So as you can see here,

00:20:05.834 --> 00:20:07.894 position:20%
T-shirts are cut and sewn

00:20:07.918 --> 00:20:10.143
garments, and that's as opposed

00:20:10.167 --> 00:20:12.768
to being knit to shape, which

00:20:12.792 --> 00:20:13.975
thankfully is outside the scope

00:20:13.999 --> 00:20:15.393
of my presentation today. Knit

00:20:15.417 --> 00:20:16.727 position:20%
to shape could be an entire

00:20:16.751 --> 00:20:18.685 position:20%
webinar in and of itself.

00:20:18.709 --> 00:20:20.393
The body of a T-shirt can be

00:20:20.417 --> 00:20:23.101
made of one piece of circular

00:20:23.125 --> 00:20:27.975
knit fabric, so no side seams,

00:20:27.999 --> 00:20:29.975
or it can be constructed from

00:20:29.999 --> 00:20:31.393
two pieces of fabric that form

00:20:31.417 --> 00:20:33.476
the front and back panels and

00:20:33.500 --> 00:20:34.852
that are sewn together at the

00:20:34.876 --> 00:20:37.351
sides. And in either case, the

00:20:37.375 --> 00:20:38.975
sleeves are each formed from one

00:20:38.999 --> 00:20:42.976
piece of fabric. And both the

00:20:43.000 --> 00:20:43.975 position:20%
sleeves and the bottom of a

00:20:43.999 --> 00:20:45.727
T-shirt are hemmed. And just to

00:20:45.751 --> 00:20:47.685
note, I've listed a ruling there

00:20:47.709 --> 00:20:49.643 position:20%
on the bottom can be either

00:20:49.667 --> 00:20:54.101
straight all the way round, or

00:20:54.125 --> 00:20:55.268 position:20%
curved.

00:20:55.292 --> 00:20:58.935
So with all that said, what I

00:20:58.959 --> 00:21:00.351
that you would I'd do for most

00:21:00.375 --> 00:21:01.101
of the rest of the time I have

00:21:01.125 --> 00:21:02.226
with you today is talk about

00:21:02.250 --> 00:21:03.685
some different garments and the

00:21:03.709 --> 00:21:05.518 position:20%
different features on those

00:21:05.542 --> 00:21:06.602 position:20%
garments that affect the

00:21:06.626 --> 00:21:09.393
classification. But the one

00:21:09.417 --> 00:21:11.268
point I'd like to make clear up

00:21:11.292 --> 00:21:13.685
front is that there really is no

00:21:13.709 --> 00:21:15.059
complete hard and fast list of

00:21:15.083 --> 00:21:17.894
features that make a particular

00:21:17.918 --> 00:21:20.476
garment a T-shirt or a garment

00:21:20.500 --> 00:21:22.768
that's similar to a T-shirt, or

00:21:22.792 --> 00:21:24.518 position:20%
that exclude a garment from

00:21:24.542 --> 00:21:28.310 position:20%
heading 6109 entirely.

00:21:28.334 --> 00:21:30.059 position:20%
As we've seen, there's

00:21:30.083 --> 00:21:31.518
basically nothing in the tariff

00:21:31.542 --> 00:21:33.810
schedule that goes to this other

00:21:33.834 --> 00:21:36.768
than that chapter 61, note 5,

00:21:36.792 --> 00:21:38.976
which I showed you on an earlier

00:21:39.000 --> 00:21:40.975 position:20%
slide, that tells us that

00:21:40.999 --> 00:21:41.975
T-shirts don't have tightening

00:21:41.999 --> 00:21:43.975 position:20%
at the bottom.

00:21:43.999 --> 00:21:45.435
And also, with the exception of

00:21:45.459 --> 00:21:46.975
one particular T-shirt tariff

00:21:46.999 --> 00:21:48.975
number that has very specific

00:21:48.999 --> 00:21:49.975
requirements, which I'll get to

00:21:49.999 --> 00:21:53.393 position:20%
in just a minute.

00:21:53.417 --> 00:21:54.852 position:20%
And again, the explanatory

00:21:54.876 --> 00:21:56.768
notes are pretty limited in this

00:21:56.792 --> 00:21:58.518
area as well. We saw this slide

00:21:58.542 --> 00:22:00.101
a couple of minutes ago, but

00:22:00.125 --> 00:22:05.852
I've put it up here again as

00:22:05.876 --> 00:22:06.975
well. So this note has some

00:22:06.999 --> 00:22:08.310
information, as I mentioned,

00:22:08.334 --> 00:22:09.810
about the types of necklines

00:22:09.834 --> 00:22:10.975
that are allowed on T-shirts,

00:22:10.999 --> 00:22:12.768
and it says the garments with

00:22:12.792 --> 00:22:15.226
buttons or other fastenings are

00:22:15.250 --> 00:22:16.560
excluded. And again, that's

00:22:16.584 --> 00:22:18.975
because underwear doesn't have

00:22:18.999 --> 00:22:21.185
buttonings or fastenings, so you

00:22:21.209 --> 00:22:22.768 position:20%
see that type of reasoning

00:22:22.792 --> 00:22:24.768
again. And the note talks a

00:22:24.792 --> 00:22:25.975
little bit about the types of

00:22:25.999 --> 00:22:27.518
decoration that are allowed, but

00:22:27.542 --> 00:22:28.975
no comprehensive list of garment

00:22:28.999 --> 00:22:32.101 position:20%
features per se.

00:22:32.125 --> 00:22:34.059
However, what we do have is a

00:22:34.083 --> 00:22:35.643
body of rulings that have been

00:22:35.667 --> 00:22:38.226
issued over the years, where a

00:22:38.250 --> 00:22:39.351 position:20%
garment was submitted for a

00:22:39.375 --> 00:22:41.975
ruling, and we at CBP and the

00:22:41.999 --> 00:22:43.810
U.S. Customs Services before

00:22:43.834 --> 00:22:45.810
that examined the construction

00:22:45.834 --> 00:22:47.894 position:20%
of the garment, the type of

00:22:47.918 --> 00:22:49.975 position:20%
fabric that was used, the

00:22:49.999 --> 00:22:51.976
different features it had, and

00:22:52.000 --> 00:22:53.810 position:20%
we made individual

00:22:53.834 --> 00:22:54.975
determinations on whether these

00:22:54.999 --> 00:22:57.976
things were consistent with the

00:22:58.000 --> 00:22:59.351
garment's basic appearance and

00:22:59.375 --> 00:23:01.476 position:20%
character as underwear, or

00:23:01.500 --> 00:23:03.643
whether these things moved the

00:23:03.667 --> 00:23:05.975
garment from classification as a

00:23:05.999 --> 00:23:08.435
true T-shirt to similar to a

00:23:08.459 --> 00:23:10.975
T-shirt, or maybe these things

00:23:10.999 --> 00:23:13.351
were even significant enough to

00:23:13.375 --> 00:23:14.975
exclude the garment from heading

00:23:14.999 --> 00:23:18.143
6109 entirely, and move it over

00:23:18.167 --> 00:23:21.059
into, most likely, a pullover in

00:23:21.083 --> 00:23:25.018 position:20%
heading 6110. And so this

00:23:25.042 --> 00:23:26.602 position:20%
process, over many years of

00:23:26.626 --> 00:23:27.975 position:20%
examining garments on a

00:23:27.999 --> 00:23:30.975
case-by-case basis and issuing

00:23:30.999 --> 00:23:32.476
rulings on them, this is what

00:23:32.500 --> 00:23:33.810 position:20%
gave rise to the lists of

00:23:33.834 --> 00:23:34.685 position:20%
features that you might be

00:23:34.709 --> 00:23:37.852 position:20%
familiar with. And these

00:23:37.876 --> 00:23:39.435 position:20%
rulings are what give legal

00:23:39.459 --> 00:23:41.059
weight, legal status, if you

00:23:41.083 --> 00:23:44.226
will, to these considerations.

00:23:44.250 --> 00:23:45.602 position:20%
But again, these are not

00:23:45.626 --> 00:23:47.185
complete lists, necessarily,

00:23:47.209 --> 00:23:48.685
because you never know when a

00:23:48.709 --> 00:23:49.975
new feature is going to show up

00:23:49.999 --> 00:23:52.393
in a garment that we've never

00:23:52.417 --> 00:23:53.643
considered before and will have

00:23:53.667 --> 00:23:55.727
to examine this new feature in

00:23:55.751 --> 00:23:58.059
terms of, again, does it detract

00:23:58.083 --> 00:23:59.894 position:20%
from the garment's basic

00:23:59.918 --> 00:24:01.143 position:20%
appearance and character as

00:24:01.167 --> 00:24:04.602 position:20%
underwear? Okay?

00:24:04.626 --> 00:24:08.975
But with all that said, I am

00:24:08.999 --> 00:24:09.935
going to start off this part of

00:24:09.959 --> 00:24:12.518
my presentation with one very

00:24:12.542 --> 00:24:14.393
specific type of T-shirt, and

00:24:14.417 --> 00:24:17.351
you will find this only under

00:24:17.375 --> 00:24:19.351
men's and boy's garments, not

00:24:19.375 --> 00:24:22.018 position:20%
women's or girls. This is

00:24:22.042 --> 00:24:26.975
Tariff Number 6109.10.0004, and

00:24:26.999 --> 00:24:27.975
I've put this section of the

00:24:27.999 --> 00:24:28.976 position:20%
tariff schedule up on this

00:24:29.000 --> 00:24:30.975 position:20%
slide.

00:24:30.999 --> 00:24:32.393 position:20%
Now, this tariff number is

00:24:32.417 --> 00:24:34.018
pretty restrictive. It provides

00:24:34.042 --> 00:24:37.185
for all white cotton T-shirts

00:24:37.209 --> 00:24:38.768
and, just to be clear here, when

00:24:38.792 --> 00:24:40.101 position:20%
we say all white, we're

00:24:40.125 --> 00:24:42.975
referring to bleached white as

00:24:42.999 --> 00:24:44.727
opposed to grayish, which would

00:24:44.751 --> 00:24:47.059
be unbleached or undyed fabric

00:24:47.083 --> 00:24:49.018
that has a natural white color.

00:24:49.042 --> 00:24:51.268
Beige garments are excluded from

00:24:51.292 --> 00:24:53.185 position:20%
this provision.

00:24:53.209 --> 00:24:54.810 position:20%
And as you can see, these

00:24:54.834 --> 00:24:57.476
garments must have short, hemmed

00:24:57.500 --> 00:24:59.768
sleeves and a hemmed bottom.

00:24:59.792 --> 00:25:01.226 position:20%
You might recall that the

00:25:01.250 --> 00:25:02.727
explanatory notes say that the

00:25:02.751 --> 00:25:04.268
bottoms of T-shirts are usually

00:25:04.292 --> 00:25:06.975
hemmed, and again, that is true

00:25:06.999 --> 00:25:08.975
for 6109 at the international

00:25:08.999 --> 00:25:11.975
level. But for garments to be

00:25:11.999 --> 00:25:13.852
classified under this particular

00:25:13.876 --> 00:25:15.643
tariff number, the bottom must

00:25:15.667 --> 00:25:17.268
be hemmed, and that's because

00:25:17.292 --> 00:25:19.393
this is specifically stated here

00:25:19.417 --> 00:25:23.976 position:20%
in the tariff schedule.

00:25:24.000 --> 00:25:27.476
Next, a few different styles of

00:25:27.500 --> 00:25:29.476
neckline are allowed here, crew,

00:25:29.500 --> 00:25:31.185
round, which is generally cut a

00:25:31.209 --> 00:25:32.059
little lower than a standard

00:25:32.083 --> 00:25:37.185
crew neck, or mitered V-neck.

00:25:37.209 --> 00:25:39.059 position:20%
And I've included photos of

00:25:39.083 --> 00:25:41.894
these types of necklines here on

00:25:41.918 --> 00:25:44.268
this slide. You can see crew is

00:25:44.292 --> 00:25:50.059
usually rib knit. Round, boat

00:25:50.083 --> 00:25:51.435
shaped is a little less common,

00:25:51.459 --> 00:25:56.643
I think, these days, and then

00:25:56.667 --> 00:25:59.810
mitered, what I mean by mitered

00:25:59.834 --> 00:26:01.975
here is the fabric at the two

00:26:01.999 --> 00:26:03.602
sides of that "V" are stitched

00:26:03.626 --> 00:26:04.935
together at the front, and you

00:26:04.959 --> 00:26:06.185
can hopefully see that in the

00:26:06.209 --> 00:26:06.810 position:20%
photo.

00:26:06.834 --> 00:26:08.518
Also, just a quick note about

00:26:08.542 --> 00:26:09.852
capping, which hopefully you can

00:26:09.876 --> 00:26:12.310
see on the photo of the round

00:26:12.334 --> 00:26:15.560
neckline. Capping on garments

00:26:15.584 --> 00:26:16.727 position:20%
of this tariff number is

00:26:16.751 --> 00:26:17.975 position:20%
acceptable, but only on the

00:26:17.999 --> 00:26:19.560
neckline, not on the sleeves,

00:26:19.584 --> 00:26:21.560
not on the bottom, anywhere else

00:26:21.584 --> 00:26:23.476
on the garment, and I am going

00:26:23.500 --> 00:26:25.852
to touch on sleeve capping a

00:26:25.876 --> 00:26:28.435 position:20%
little later on.

00:26:28.459 --> 00:26:29.518 position:20%
And then finally, I'm just

00:26:29.542 --> 00:26:32.768
going to go back to the rest of

00:26:32.792 --> 00:26:34.560
that tariff description just so

00:26:34.584 --> 00:26:39.852
you can see, no pockets, trim or

00:26:39.876 --> 00:26:41.975
embroidery are allowed under

00:26:41.999 --> 00:26:42.976
this particular tariff number,

00:26:43.000 --> 00:26:44.101
which you can see here at the

00:26:44.125 --> 00:26:49.268 position:20%
end of the description.

00:26:49.292 --> 00:26:51.643 position:20%
So this is really the most

00:26:51.667 --> 00:26:52.975
restrictive tariff number we

00:26:52.999 --> 00:26:56.310
have as far as T-shirts. And

00:26:56.334 --> 00:26:58.560
essentially, it defines your

00:26:58.584 --> 00:27:00.602
basic men's underwear garment,

00:27:00.626 --> 00:27:02.727 position:20%
which you see here. And

00:27:02.751 --> 00:27:05.643
actually, if a garment meets all

00:27:05.667 --> 00:27:08.226
of these criteria, it will be

00:27:08.250 --> 00:27:09.643 position:20%
classified in tariff number

00:27:09.667 --> 00:27:14.975 position:20%
6109.10.0004, whether it is

00:27:14.999 --> 00:27:18.768
truly underwear or an article of

00:27:18.792 --> 00:27:21.935 position:20%
conventional attire that is

00:27:21.959 --> 00:27:24.059
suitable to be worn outdoors, in

00:27:24.083 --> 00:27:25.101 position:20%
public.

00:27:25.125 --> 00:27:26.975
The tariff schedule makes no

00:27:26.999 --> 00:27:29.975
distinction between underwear

00:27:29.999 --> 00:27:34.018
and traditionally conventional

00:27:34.042 --> 00:27:35.518
attire when it comes to these

00:27:35.542 --> 00:27:37.393 position:20%
T-shirts. Okay?

00:27:37.417 --> 00:27:40.101
But there can be other types of

00:27:40.125 --> 00:27:41.643 position:20%
men's garments as well that

00:27:41.667 --> 00:27:44.975
might not meet every one of the

00:27:44.999 --> 00:27:45.975
restrictive criteria that we

00:27:45.999 --> 00:27:48.101 position:20%
just went over, but they're

00:27:48.125 --> 00:27:51.976
still classified as T-shirts.

00:27:52.000 --> 00:27:53.643
And these garments would fall

00:27:53.667 --> 00:27:56.226
into the tariff provision for

00:27:56.250 --> 00:27:58.018 position:20%
other T-shirts. And I've

00:27:58.042 --> 00:27:58.976
included that section of the

00:27:59.000 --> 00:28:00.101
tariff schedule here. So you

00:28:00.125 --> 00:28:04.101
can see what I'm referring to.

00:28:04.125 --> 00:28:05.518
Now, a T-shirt that falls into

00:28:05.542 --> 00:28:09.476
one of these provisions might,

00:28:09.500 --> 00:28:10.852
for example, be a color other

00:28:10.876 --> 00:28:13.476
than white. It might be dyed

00:28:13.500 --> 00:28:15.560
red or blue or more than one

00:28:15.584 --> 00:28:17.268
color, or maybe it has a chest

00:28:17.292 --> 00:28:19.727
pocket. But it doesn't have any

00:28:19.751 --> 00:28:21.393
features that would exclude it

00:28:21.417 --> 00:28:23.185 position:20%
from classification as a

00:28:23.209 --> 00:28:26.975
T-shirt. And again, what do I

00:28:26.999 --> 00:28:27.976
mean by that? Nothing about

00:28:28.000 --> 00:28:29.143
these garments is inconsistent

00:28:29.167 --> 00:28:33.727 position:20%
with underwear.

00:28:33.751 --> 00:28:34.975
And here I just thought I would

00:28:34.999 --> 00:28:36.852
take a minute and mention screen

00:28:36.876 --> 00:28:37.975
printing in particular and how

00:28:37.999 --> 00:28:39.310 position:20%
it relates to T-shirt

00:28:39.334 --> 00:28:41.268
classification, because I do get

00:28:41.292 --> 00:28:43.476
a lot of questions about this,

00:28:43.500 --> 00:28:44.975
and actually this was a topic

00:28:44.999 --> 00:28:46.768 position:20%
that someone in the trade

00:28:46.792 --> 00:28:47.435
specifically requested that I

00:28:47.459 --> 00:28:50.602 position:20%
cover.

00:28:50.626 --> 00:28:52.685
So the good news here is that

00:28:52.709 --> 00:28:53.935
screen printing is actually not

00:28:53.959 --> 00:28:55.810
a big deal. It is acceptable on

00:28:55.834 --> 00:28:58.894
T-shirts. And the same goes for

00:28:58.918 --> 00:29:00.351
digital printing, which is a

00:29:00.375 --> 00:29:01.727
newer method of printing that

00:29:01.751 --> 00:29:02.894
some of you might be familiar

00:29:02.918 --> 00:29:05.351 position:20%
with. And these types of

00:29:05.375 --> 00:29:07.059
printing can take the form of a

00:29:07.083 --> 00:29:08.602 position:20%
design on the front of the

00:29:08.626 --> 00:29:09.602
garment, as you can see on the

00:29:09.626 --> 00:29:11.435
left, and the size of the design

00:29:11.459 --> 00:29:13.975
doesn't matter. Small, large

00:29:13.999 --> 00:29:15.643
and everything in between are

00:29:15.667 --> 00:29:19.560
all acceptable. Or can even be

00:29:19.584 --> 00:29:21.351
an all-over print, which you can

00:29:21.375 --> 00:29:22.975
see on the garment on the right.

00:29:22.999 --> 00:29:24.393
So the entire garment can be

00:29:24.417 --> 00:29:26.643 position:20%
screen printed and still be

00:29:26.667 --> 00:29:29.975
classified as a T-shirt. And I

00:29:29.999 --> 00:29:30.852 position:20%
think this is what might be

00:29:30.876 --> 00:29:31.975
causing some of the confusion

00:29:31.999 --> 00:29:33.975
with screen printing, because

00:29:33.999 --> 00:29:35.976 position:20%
this is different from heat

00:29:36.000 --> 00:29:37.518 position:20%
seals and other kinds of

00:29:37.542 --> 00:29:39.351
decoration and embellishment,

00:29:39.375 --> 00:29:40.727
which I'll be talking about in a

00:29:40.751 --> 00:29:43.101
few minutes. But the important

00:29:43.125 --> 00:29:44.602
thing to remember about screen

00:29:44.626 --> 00:29:46.975
printing is that it must be flat

00:29:46.999 --> 00:29:48.975
on the garment. It can't be

00:29:48.999 --> 00:29:49.975 position:20%
raised. It can't be

00:29:49.999 --> 00:29:52.185
three-dimensional. And why do

00:29:52.209 --> 00:29:53.975
you suppose that is? I know I'm

00:29:53.999 --> 00:29:55.518
probably starting to sound like

00:29:55.542 --> 00:29:57.975
a broken record. Are any of you

00:29:57.999 --> 00:29:59.975
aware of actual underwear that

00:29:59.999 --> 00:30:01.518 position:20%
has raised printing on the

00:30:01.542 --> 00:30:05.310
surface? Please say no because

00:30:05.334 --> 00:30:06.976
that would be inconsistent with

00:30:07.000 --> 00:30:10.518 position:20%
underwear.

00:30:10.542 --> 00:30:13.226
So again, the reasoning behind

00:30:13.250 --> 00:30:14.685 position:20%
allowing screen printing or

00:30:14.709 --> 00:30:16.810
digital printing on T-shirts is

00:30:16.834 --> 00:30:17.976 position:20%
that because these types of

00:30:18.000 --> 00:30:19.810 position:20%
printing result in a flat

00:30:19.834 --> 00:30:22.393
design, it doesn't detract from

00:30:22.417 --> 00:30:24.268
the garment's basic character as

00:30:24.292 --> 00:30:26.810
underwear. And I'm going to be

00:30:26.834 --> 00:30:28.393
talking a little bit more about

00:30:28.417 --> 00:30:29.975
some different kinds of printing

00:30:29.999 --> 00:30:34.560 position:20%
a little later on. Okay?

00:30:34.584 --> 00:30:38.602 position:20%
But, next up. Moving down

00:30:38.626 --> 00:30:41.975
heading 6109, there is also a

00:30:41.999 --> 00:30:44.560
provision for garments that we

00:30:44.584 --> 00:30:46.975 position:20%
consider to be not actual

00:30:46.999 --> 00:30:48.602
T-shirts per se because there

00:30:48.626 --> 00:30:51.101
might be one or two features on

00:30:51.125 --> 00:30:52.975 position:20%
the garment that aren't

00:30:52.999 --> 00:30:53.768 position:20%
consistent with actual

00:30:53.792 --> 00:30:56.476
underwear, but these features

00:30:56.500 --> 00:30:58.268
really don't take away in any

00:30:58.292 --> 00:30:59.518 position:20%
significant way from the

00:30:59.542 --> 00:31:01.643
garment's basic similarity to a

00:31:01.667 --> 00:31:02.810
T-shirt. And as you can see on

00:31:02.834 --> 00:31:04.435
this slide, this is where the

00:31:04.459 --> 00:31:06.935
ten-digit breakout for other

00:31:06.959 --> 00:31:08.393
garments comes in to play. And

00:31:08.417 --> 00:31:10.226 position:20%
I've included excerpts from

00:31:10.250 --> 00:31:11.975 position:20%
heading 6109 at the tariff

00:31:11.999 --> 00:31:13.975 position:20%
schedule for both cotton

00:31:13.999 --> 00:31:16.894
garments and then man-made fiber

00:31:16.918 --> 00:31:18.476
garments down toward the bottom

00:31:18.500 --> 00:31:20.518
of that screen to show you where

00:31:20.542 --> 00:31:24.185 position:20%
these provisions are.

00:31:24.209 --> 00:31:25.560
And the word we've come to use

00:31:25.584 --> 00:31:26.852
when we're talking about these

00:31:26.876 --> 00:31:29.602 position:20%
types of garments is

00:31:29.626 --> 00:31:31.976
inconspicuous. These features

00:31:32.000 --> 00:31:34.268
are inconspicuous, and the way

00:31:34.292 --> 00:31:36.059
we handle these features from a

00:31:36.083 --> 00:31:37.975
classification perspective is

00:31:37.999 --> 00:31:40.810
that a garment may have no more

00:31:40.834 --> 00:31:43.351
than two of these features in

00:31:43.375 --> 00:31:45.101
order to still be classified as

00:31:45.125 --> 00:31:47.894
similar to a T-shirt in that

00:31:47.918 --> 00:31:51.101
other provision. And garments

00:31:51.125 --> 00:31:52.975
that do have more than two of

00:31:52.999 --> 00:31:54.059
these features usually end up

00:31:54.083 --> 00:31:56.143
being classified in heading 6110

00:31:56.167 --> 00:31:59.101 position:20%
as a pullover.

00:31:59.125 --> 00:32:01.975
And here on this next slide, as

00:32:01.999 --> 00:32:04.476
I promised, I have included a

00:32:04.500 --> 00:32:05.810 position:20%
partial list of these

00:32:05.834 --> 00:32:07.351
inconspicuous features so you

00:32:07.375 --> 00:32:08.975
can get an idea of the kinds of

00:32:08.999 --> 00:32:11.310
things I'm talking about, but

00:32:11.334 --> 00:32:13.727 position:20%
again, this list is not all

00:32:13.751 --> 00:32:14.975
inclusive, and you won't find

00:32:14.999 --> 00:32:16.975
them listed in the tariff or the

00:32:16.999 --> 00:32:17.976
explanatory notes or even the

00:32:18.000 --> 00:32:24.727
ICP. There is no hard and fast

00:32:24.751 --> 00:32:25.894 position:20%
comprehensive list of these

00:32:25.918 --> 00:32:27.101 position:20%
features. As I mentioned

00:32:27.125 --> 00:32:28.185
earlier, the only reason we have

00:32:28.209 --> 00:32:30.101
this list is because we at CBP

00:32:30.125 --> 00:32:32.975
and the Custom Service before

00:32:32.999 --> 00:32:35.435
that, developed it ourselves by

00:32:35.459 --> 00:32:36.101
examining individual garments

00:32:36.125 --> 00:32:38.435
that had these features, and

00:32:38.459 --> 00:32:40.727
viewing each of them with an eye

00:32:40.751 --> 00:32:41.975 position:20%
toward is this feature

00:32:41.999 --> 00:32:45.602
consistent with underwear or

00:32:45.626 --> 00:32:47.351 position:20%
does it detract from the

00:32:47.375 --> 00:32:49.143
garment's basic appearance and

00:32:49.167 --> 00:32:51.226
character as underwear, and then

00:32:51.250 --> 00:32:53.018
we classified it accordingly.

00:32:53.042 --> 00:32:54.852
And so here are some of those

00:32:54.876 --> 00:32:56.643
features. Features that customs

00:32:56.667 --> 00:32:58.975
has previously determined to be

00:32:58.999 --> 00:33:01.476 position:20%
inconspicuous non-T-shirt

00:33:01.500 --> 00:33:02.975
features. And I'm going to be

00:33:02.999 --> 00:33:04.975
going through this list on the

00:33:04.999 --> 00:33:07.975
following few slides, and I'm

00:33:07.999 --> 00:33:08.976
showing you photos of them. But

00:33:09.000 --> 00:33:10.310
these first items on the list

00:33:10.334 --> 00:33:11.975
are really the ones I get the

00:33:11.999 --> 00:33:14.975
most questions about. A small

00:33:14.999 --> 00:33:17.852
heat seal, small label and so

00:33:17.876 --> 00:33:18.975
forth. And so I just want to

00:33:18.999 --> 00:33:20.476
take a minute here and make sure

00:33:20.500 --> 00:33:21.975
that everyone understands the

00:33:21.999 --> 00:33:23.435 position:20%
difference between these

00:33:23.459 --> 00:33:25.560
features, especially heat seals,

00:33:25.584 --> 00:33:26.935
and screen printing, which I

00:33:26.959 --> 00:33:29.518 position:20%
just talked about.

00:33:29.542 --> 00:33:32.018
So again, for screen printing,

00:33:32.042 --> 00:33:33.768
the size of the print doesn't

00:33:33.792 --> 00:33:35.975 position:20%
matter. Small, large and

00:33:35.999 --> 00:33:37.935
all-over pattern. All of these

00:33:37.959 --> 00:33:41.059
are acceptable on T-shirts. But

00:33:41.083 --> 00:33:43.393
for heat seals, which you can

00:33:43.417 --> 00:33:48.476
see here on this slide, these

00:33:48.500 --> 00:33:49.975
are different, because unlike

00:33:49.999 --> 00:33:51.852 position:20%
screen printing or digital

00:33:51.876 --> 00:33:53.351
printing, a heat seal is not

00:33:53.375 --> 00:33:54.976 position:20%
flat on the surface of the

00:33:55.000 --> 00:33:57.351
fabric. Even if it's small, it

00:33:57.375 --> 00:33:59.476
has an identity prior to being

00:33:59.500 --> 00:34:00.975
applied to the garment. It's

00:34:00.999 --> 00:34:02.810
already a finished thing, if you

00:34:02.834 --> 00:34:05.393 position:20%
will, and again, once it's

00:34:05.417 --> 00:34:07.351
applied, it results in a raised

00:34:07.375 --> 00:34:08.894
surface on the fabric of the

00:34:08.918 --> 00:34:12.894
garment. And because underwear

00:34:12.918 --> 00:34:14.351 position:20%
garments do not have raised

00:34:14.375 --> 00:34:16.518
surfaces on them, this is why

00:34:16.542 --> 00:34:18.185
heat seals are considered to be

00:34:18.209 --> 00:34:21.435
non-T-shirt features. And I'll

00:34:21.459 --> 00:34:22.351
be getting into this a little

00:34:22.375 --> 00:34:24.518
more later, but this is also why

00:34:24.542 --> 00:34:25.975
the size of the heat seal comes

00:34:25.999 --> 00:34:28.976
in to play when we're trying to

00:34:29.000 --> 00:34:30.393 position:20%
decide whether it's an

00:34:30.417 --> 00:34:33.101
inconspicuous or a conspicuous

00:34:33.125 --> 00:34:37.101
non-T-shirt feature. Okay? And

00:34:37.125 --> 00:34:37.975
so as you can see here on the

00:34:37.999 --> 00:34:39.975
bottom photo, this reasoning

00:34:39.999 --> 00:34:44.310
also applies to small labels,

00:34:44.334 --> 00:34:49.975
and also to small embroideries

00:34:49.999 --> 00:34:54.268
and appliques, which you can see

00:34:54.292 --> 00:34:56.059
on this next slide. And as far

00:34:56.083 --> 00:34:57.476 position:20%
as other features on that

00:34:57.500 --> 00:34:59.975
inconspicuous list, I'm going to

00:34:59.999 --> 00:35:02.226
just go quickly through these

00:35:02.250 --> 00:35:03.975 position:20%
next few slides to show you

00:35:03.999 --> 00:35:05.185 position:20%
photos of these features.

00:35:05.209 --> 00:35:08.975 position:20%
So long sleeves -- and

00:35:08.999 --> 00:35:10.435 position:20%
remember, we saw that long

00:35:10.459 --> 00:35:11.810 position:20%
sleeves were listed in the

00:35:11.834 --> 00:35:12.975
explanatory notes as acceptable

00:35:12.999 --> 00:35:16.351
on T-shirts. But again, that's

00:35:16.375 --> 00:35:17.268
only for the international level

00:35:17.292 --> 00:35:22.975
of 6109. But for U.S. garments,

00:35:22.999 --> 00:35:24.975
garments with long sleeves are

00:35:24.999 --> 00:35:26.018
classified within that other

00:35:26.042 --> 00:35:27.685
provision rather than as true

00:35:27.709 --> 00:35:31.727
T-shirts. Raglan sleeves, which

00:35:31.751 --> 00:35:33.768
you can also see here, these are

00:35:33.792 --> 00:35:39.143
sleeves that have a diagonal

00:35:39.167 --> 00:35:41.476
seem that extends from the next

00:35:41.500 --> 00:35:42.975 position:20%
line of the garment to the

00:35:42.999 --> 00:35:49.310
underarm. Next forward shoulder

00:35:49.334 --> 00:35:51.975
seams, which you can see on the

00:35:51.999 --> 00:35:53.975
photo on the right, this is also

00:35:53.999 --> 00:35:56.852
an inconspicuous non-T-shirt

00:35:56.876 --> 00:35:58.975
feature, and this is actually a

00:35:58.999 --> 00:36:00.101
ruling that I did a few years

00:36:00.125 --> 00:36:03.518 position:20%
ago. Moving on, ridging on

00:36:03.542 --> 00:36:05.975
sleeves, you can see the true

00:36:05.999 --> 00:36:07.101 position:20%
T-shirts have short hemmed

00:36:07.125 --> 00:36:08.101 position:20%
sleeves. And capping. So

00:36:08.125 --> 00:36:09.476
remember that a garment can have

00:36:09.500 --> 00:36:11.975 position:20%
capping on the neckline and

00:36:11.999 --> 00:36:13.975 position:20%
still be classified as a

00:36:13.999 --> 00:36:17.476 position:20%
T-shirt. A capping on the

00:36:17.500 --> 00:36:18.975
sleeves or bottom moves it over

00:36:18.999 --> 00:36:21.727 position:20%
into that other subheading.

00:36:21.751 --> 00:36:26.018
On the next slide, crossover

00:36:26.042 --> 00:36:27.185 position:20%
neck bands, also an

00:36:27.209 --> 00:36:29.268
inconspicuous feature. And I

00:36:29.292 --> 00:36:30.975
just want to point out here that

00:36:30.999 --> 00:36:32.560
these are different than the

00:36:32.584 --> 00:36:36.018
mitered V-neck necklines which

00:36:36.042 --> 00:36:37.602 position:20%
we saw earlier, which are

00:36:37.626 --> 00:36:38.975 position:20%
acceptable on T-shirts.

00:36:38.999 --> 00:36:40.975
And then just to finish up with

00:36:40.999 --> 00:36:42.894
the rest of the items on that

00:36:42.918 --> 00:36:46.975 position:20%
list, if a garment has side

00:36:46.999 --> 00:36:49.226
slits or a longer back panel,

00:36:49.250 --> 00:36:50.602
which you can see here, these

00:36:50.626 --> 00:36:52.975 position:20%
are also inconspicuous

00:36:52.999 --> 00:36:57.975
non-T-shirt features, as are

00:36:57.999 --> 00:37:00.975
hanger loops and sweat patches

00:37:00.999 --> 00:37:02.975
at the inner rear neckline of

00:37:02.999 --> 00:37:06.852
the garment. So those are all

00:37:06.876 --> 00:37:08.727 position:20%
examples of inconspicuous

00:37:08.751 --> 00:37:09.975
non-T-shirt features. Those are

00:37:09.999 --> 00:37:11.476
the only ones I'm going to show

00:37:11.500 --> 00:37:14.602 position:20%
you today. But just to

00:37:14.626 --> 00:37:16.476 position:20%
reiterate, this list is not

00:37:16.500 --> 00:37:18.226
exhaustive. These features are

00:37:18.250 --> 00:37:19.435 position:20%
just examples taken from

00:37:19.459 --> 00:37:21.975 position:20%
garments that I and my

00:37:21.999 --> 00:37:23.476 position:20%
predecessors have ruled on.

00:37:23.500 --> 00:37:24.975
There are more of these features

00:37:24.999 --> 00:37:27.393
out there. Or who knows, you

00:37:27.417 --> 00:37:29.101
might come across a new one,

00:37:29.125 --> 00:37:30.727
because as you know, fashion is

00:37:30.751 --> 00:37:32.143
constantly evolving, right? So

00:37:32.167 --> 00:37:34.185
we may be adding your feature to

00:37:34.209 --> 00:37:35.143 position:20%
that list.

00:37:35.167 --> 00:37:37.810
Okay. But now, I am going to

00:37:37.834 --> 00:37:39.852
move on to the last portion of

00:37:39.876 --> 00:37:42.351
my presentation -- I know you're

00:37:42.375 --> 00:37:43.935
all excited -- and I'm going to

00:37:43.959 --> 00:37:46.685 position:20%
talk a little bit about

00:37:46.709 --> 00:37:49.476 position:20%
conspicuous non-T-shirt

00:37:49.500 --> 00:37:51.226 position:20%
features. And these are

00:37:51.250 --> 00:37:52.852 position:20%
features that do detract

00:37:52.876 --> 00:37:53.768
significantly from a garment's

00:37:53.792 --> 00:37:56.143
basic character and appearance

00:37:56.167 --> 00:37:57.935
as underwear. Now, the garment

00:37:57.959 --> 00:37:59.975
might still resemble a T-shirt,

00:37:59.999 --> 00:38:02.435
but in this case, the feature or

00:38:02.459 --> 00:38:04.310 position:20%
features it has make it

00:38:04.334 --> 00:38:06.226
different enough from underwear

00:38:06.250 --> 00:38:07.351 position:20%
that we've made the

00:38:07.375 --> 00:38:08.976
determination that it's not a

00:38:09.000 --> 00:38:11.476
T-shirt or a similar item within

00:38:11.500 --> 00:38:15.185 position:20%
heading 6109.

00:38:15.209 --> 00:38:16.268
And an important thing to keep

00:38:16.292 --> 00:38:18.476
in mind here is that even one of

00:38:18.500 --> 00:38:20.268 position:20%
these features on a garment

00:38:20.292 --> 00:38:22.975
would preclude that garment from

00:38:22.999 --> 00:38:24.975
classification as a T-shirt or a

00:38:24.999 --> 00:38:27.975
similar garment in 6109, and

00:38:27.999 --> 00:38:30.059
move it over, again, most likely

00:38:30.083 --> 00:38:31.435
into the other subheading of

00:38:31.459 --> 00:38:35.351 position:20%
6110 as a pullover.

00:38:35.375 --> 00:38:38.727
And so on this next slide, I

00:38:38.751 --> 00:38:40.476 position:20%
have tried to list the most

00:38:40.500 --> 00:38:42.602
common of these features, but

00:38:42.626 --> 00:38:44.810 position:20%
again, this list is not all

00:38:44.834 --> 00:38:48.018
inclusive. Rather, it's a list

00:38:48.042 --> 00:38:49.852 position:20%
that we have -- at CBP have

00:38:49.876 --> 00:38:50.975 position:20%
developed, based on rulings

00:38:50.999 --> 00:38:52.476
we've done on garments that have

00:38:52.500 --> 00:38:54.975 position:20%
had these features.

00:38:54.999 --> 00:38:56.975
So starting off this list is

00:38:56.999 --> 00:38:58.727
the feature I mentioned earlier,

00:38:58.751 --> 00:38:59.727 position:20%
and that has to do with the

00:38:59.751 --> 00:39:01.101 position:20%
weight of the fabric of a

00:39:01.125 --> 00:39:04.727
garment. So if a garment is

00:39:04.751 --> 00:39:05.476 position:20%
constructed of fabric that

00:39:05.500 --> 00:39:07.975
weighs more than 200 grams per

00:39:07.999 --> 00:39:09.975
square meter, that precludes its

00:39:09.999 --> 00:39:11.518
classification as a T-shirt.

00:39:11.542 --> 00:39:12.976
And again, that headquarters

00:39:13.000 --> 00:39:14.310
ruling we saw earlier provides

00:39:14.334 --> 00:39:17.810
the legal basis for this. Or if

00:39:17.834 --> 00:39:19.435
a garment is oversized. Same

00:39:19.459 --> 00:39:21.268 position:20%
thing. We regard that as a

00:39:21.292 --> 00:39:23.143
non-T-shirt feature or similar

00:39:23.167 --> 00:39:26.518
garment. And then as far as the

00:39:26.542 --> 00:39:28.435
rest of the features on this

00:39:28.459 --> 00:39:30.727
list, I've included photos and

00:39:30.751 --> 00:39:31.975
some more information on the

00:39:31.999 --> 00:39:34.435
next few slides, so I'd like to

00:39:34.459 --> 00:39:41.894 position:20%
just go through those now.

00:39:41.918 --> 00:39:42.975 position:20%
And so as I talked about

00:39:42.999 --> 00:39:44.560
earlier, a garment made of any

00:39:44.584 --> 00:39:46.059
fabric other than plain jersey

00:39:46.083 --> 00:39:48.602 position:20%
or plain interlock is not

00:39:48.626 --> 00:39:50.852
classifiable in heading 6109.

00:39:50.876 --> 00:39:53.101
Usually what I see come in here

00:39:53.125 --> 00:39:56.143 position:20%
is mesh-knit fabric. The

00:39:56.167 --> 00:39:57.602
garment could be styled like a

00:39:57.626 --> 00:39:59.727
T-shirt in every other way, but

00:39:59.751 --> 00:40:01.852 position:20%
if the fabric is mesh, it's

00:40:01.876 --> 00:40:03.351
pretty much a given it will end

00:40:03.375 --> 00:40:05.602 position:20%
up in 6110.

00:40:05.626 --> 00:40:07.018
Also, sleeves, which I talked

00:40:07.042 --> 00:40:09.975
about earlier as well, a true

00:40:09.999 --> 00:40:12.185 position:20%
T-shirt is a short-sleeved

00:40:12.209 --> 00:40:15.351
garment. A long-sleeved garment

00:40:15.375 --> 00:40:16.975 position:20%
will fall into similar to a

00:40:16.999 --> 00:40:18.975 position:20%
T-shirt, but anything in

00:40:18.999 --> 00:40:21.059 position:20%
between. So elbow length,

00:40:21.083 --> 00:40:23.268
three-quarter length sleeves,

00:40:23.292 --> 00:40:25.768
moves that garment out of 6109

00:40:25.792 --> 00:40:27.935 position:20%
entirely. And again, most

00:40:27.959 --> 00:40:33.018 position:20%
likely into 6110. And

00:40:33.042 --> 00:40:34.268
sleeveless garments will usually

00:40:34.292 --> 00:40:35.975
fall in 6110 as well and that is

00:40:35.999 --> 00:40:37.975
actually per the explanatory

00:40:37.999 --> 00:40:41.894
note for 6109, which excludes

00:40:41.918 --> 00:40:42.976
sleeveless garments from heading

00:40:43.000 --> 00:40:48.810 position:20%
6109.

00:40:48.834 --> 00:40:49.935
And then next I did just want

00:40:49.959 --> 00:40:51.975
to circle back to printing for a

00:40:51.999 --> 00:40:53.143
minute because, again, this is

00:40:53.167 --> 00:40:55.685
one of the things I think may

00:40:55.709 --> 00:40:57.976
cause the most confusion. So

00:40:58.000 --> 00:41:00.101
you remember how I talked about

00:41:00.125 --> 00:41:01.768 position:20%
screen printing and digital

00:41:01.792 --> 00:41:02.975
printing, and I said these types

00:41:02.999 --> 00:41:04.975
of printing are acceptable on

00:41:04.999 --> 00:41:06.393
T-shirts because they result in

00:41:06.417 --> 00:41:09.143
a flat design. Well, there are

00:41:09.167 --> 00:41:10.975
other types of printing where

00:41:10.999 --> 00:41:14.975
this is not the case. One type

00:41:14.999 --> 00:41:15.975
that seems to be making a bit of

00:41:15.999 --> 00:41:17.975 position:20%
a comeback lately is puff

00:41:17.999 --> 00:41:20.226
printing. And I've listed gel

00:41:20.250 --> 00:41:21.894
printing here as well, but that

00:41:21.918 --> 00:41:22.975 position:20%
doesn't seem to be quite as

00:41:22.999 --> 00:41:25.310
common these days. And these

00:41:25.334 --> 00:41:27.310
kinds of printing are different

00:41:27.334 --> 00:41:31.018
because they result in a raised,

00:41:31.042 --> 00:41:32.976
three-dimensional design on the

00:41:33.000 --> 00:41:34.268 position:20%
surface of the fabric.

00:41:34.292 --> 00:41:35.560 position:20%
Now, I've included a little

00:41:35.584 --> 00:41:36.975
information on puff printing

00:41:36.999 --> 00:41:39.602
from a ruling that we've done.

00:41:39.626 --> 00:41:42.685
So basically puff ink contains

00:41:42.709 --> 00:41:44.602
blowing agents that expand after

00:41:44.626 --> 00:41:46.101 position:20%
the ink is applied to the

00:41:46.125 --> 00:41:47.852 position:20%
garment, and this expansion

00:41:47.876 --> 00:41:51.226
results in a three-dimensional

00:41:51.250 --> 00:41:52.560
design. And here you can see a

00:41:52.584 --> 00:41:54.226
photo of the type of printing

00:41:54.250 --> 00:41:56.101
I'm talking about, and hopefully

00:41:56.125 --> 00:41:57.101
you can see how those letters

00:41:57.125 --> 00:42:00.143
are raised off the surface of

00:42:00.167 --> 00:42:01.101 position:20%
the fabric.

00:42:01.125 --> 00:42:02.935 position:20%
Again, this is inconsistent

00:42:02.959 --> 00:42:04.975
with underwear. That's my big

00:42:04.999 --> 00:42:09.975 position:20%
refrain for today. Okay?

00:42:09.999 --> 00:42:11.018
And then just moving on down

00:42:11.042 --> 00:42:12.975 position:20%
that list of conspicuous

00:42:12.999 --> 00:42:16.975
features, pieced construction or

00:42:16.999 --> 00:42:18.518 position:20%
inserts on a garment are

00:42:18.542 --> 00:42:20.476 position:20%
considered conspicuous

00:42:20.500 --> 00:42:22.602
non-T-shirt features, and that's

00:42:22.626 --> 00:42:24.310
because, as I mentioned earlier,

00:42:24.334 --> 00:42:26.768 position:20%
the body of a T-shirt is

00:42:26.792 --> 00:42:28.975
constructed of a front panel and

00:42:28.999 --> 00:42:30.975
a back panel, or even just one

00:42:30.999 --> 00:42:33.435
piece of circular knit fabric.

00:42:33.459 --> 00:42:34.975
Very simple, base construction

00:42:34.999 --> 00:42:35.894 position:20%
that's consistent with

00:42:35.918 --> 00:42:38.975 position:20%
underwear. But you start

00:42:38.999 --> 00:42:40.185 position:20%
getting into more extensive

00:42:40.209 --> 00:42:42.602
designs, inserts into the panels

00:42:42.626 --> 00:42:43.602 position:20%
and so forth, that goes

00:42:43.626 --> 00:42:45.185
significantly beyond what an

00:42:45.209 --> 00:42:47.976 position:20%
underwear garment would be.

00:42:48.000 --> 00:42:50.476 position:20%
The same goes for overlays.

00:42:50.500 --> 00:42:52.185 position:20%
Large labels. Large

00:42:52.209 --> 00:42:53.975
embroideries, heat seals and so

00:42:53.999 --> 00:42:54.476 position:20%
forth.

00:42:54.500 --> 00:42:55.976
Remember, I talked about small

00:42:56.000 --> 00:43:00.894
labels, embroideries, appliques,

00:43:00.918 --> 00:43:03.643
being inconspicuous, non-T-shirt

00:43:03.667 --> 00:43:04.976
features, but if they're large,

00:43:05.000 --> 00:43:06.975
they become conspicuous and they

00:43:06.999 --> 00:43:08.975
move the garment out of 6109

00:43:08.999 --> 00:43:11.602 position:20%
entirely. Okay?

00:43:11.626 --> 00:43:14.685
Moving on, here are some more

00:43:14.709 --> 00:43:16.602
things from that list. Most of

00:43:16.626 --> 00:43:19.852
these features have to do with

00:43:19.876 --> 00:43:21.935
necklines, so double neck bands,

00:43:21.959 --> 00:43:24.351
woven neck bands, turtle necks,

00:43:24.375 --> 00:43:26.602 position:20%
mock turtle necks, all

00:43:26.626 --> 00:43:28.393 position:20%
conspicuous non-T-shirt

00:43:28.417 --> 00:43:30.310 position:20%
features. And rolled neck

00:43:30.334 --> 00:43:31.852
bands, as well, as you can see

00:43:31.876 --> 00:43:33.310
here, but really any rolled edge

00:43:33.334 --> 00:43:35.602
on any part of the government.

00:43:35.626 --> 00:43:38.518
So the sleeves are the bottom.

00:43:38.542 --> 00:43:40.727 position:20%
Any of these are considered

00:43:40.751 --> 00:43:42.435 position:20%
conspicuous, non-T-shirt

00:43:42.459 --> 00:43:43.643 position:20%
features as well.

00:43:43.667 --> 00:43:45.476 position:20%
And then finally, just to

00:43:45.500 --> 00:43:48.101 position:20%
finish up, what we call

00:43:48.125 --> 00:43:51.101
non-functional or decorative

00:43:51.125 --> 00:43:53.768
overlap stitching. This is a

00:43:53.792 --> 00:43:54.975
conspicuous non-T-shirt feature

00:43:54.999 --> 00:43:56.226
as well and you can hopefully

00:43:56.250 --> 00:43:58.059
see what I mean by looking at

00:43:58.083 --> 00:44:01.727 position:20%
the top photo. So if the

00:44:01.751 --> 00:44:03.518
overlap stitching is actually

00:44:03.542 --> 00:44:05.101 position:20%
what's holding the garment

00:44:05.125 --> 00:44:06.268 position:20%
together, that's one thing.

00:44:06.292 --> 00:44:08.975
That's functional. But if you

00:44:08.999 --> 00:44:10.059
can unravel that stitching and

00:44:10.083 --> 00:44:12.226
see that there's other stitching

00:44:12.250 --> 00:44:13.351
underneath, and that's how the

00:44:13.375 --> 00:44:16.975
garment was sewn together, and

00:44:16.999 --> 00:44:17.975
in that case, the top stitching

00:44:17.999 --> 00:44:19.101
would move the garment out of a

00:44:19.125 --> 00:44:23.976 position:20%
T-shirt classification.

00:44:24.000 --> 00:44:25.435
And then finally, any pocket on

00:44:25.459 --> 00:44:26.560 position:20%
the garment other than a

00:44:26.584 --> 00:44:28.310
regular, plain, normal-sized

00:44:28.334 --> 00:44:30.975
chest pocket. So say a pocket

00:44:30.999 --> 00:44:32.768
on the sleeve, like you can see

00:44:32.792 --> 00:44:34.101
on the garment on the left, or

00:44:34.125 --> 00:44:36.975
that very large pocket on the

00:44:36.999 --> 00:44:38.435 position:20%
chest of the garment on the

00:44:38.459 --> 00:44:42.894 position:20%
right side. These would be

00:44:42.918 --> 00:44:44.143
considered a decorative styling

00:44:44.167 --> 00:44:49.226 position:20%
feature. So again, so

00:44:49.250 --> 00:44:50.101
inconsistent with underwear that

00:44:50.125 --> 00:44:52.393 position:20%
it would be a conspicuous

00:44:52.417 --> 00:44:54.059 position:20%
non-T-shirt feature.

00:44:54.083 --> 00:44:58.226
Okay? So those were kind of

00:44:58.250 --> 00:44:59.852
some long list of features that

00:44:59.876 --> 00:45:01.768
we've gone through today, and as

00:45:01.792 --> 00:45:03.310
I said, that's not even all of

00:45:03.334 --> 00:45:05.018
them. Okay? But if you're ever

00:45:05.042 --> 00:45:08.018 position:20%
not sure about a particular

00:45:08.042 --> 00:45:09.101
feature that you've come across,

00:45:09.125 --> 00:45:11.975
you can look up previous rulings

00:45:11.999 --> 00:45:13.975
in cross and see if you can find

00:45:13.999 --> 00:45:15.351
anything that sounds like it

00:45:15.375 --> 00:45:16.975
might be similar to what you

00:45:16.999 --> 00:45:18.975 position:20%
have, or if it's really not

00:45:18.999 --> 00:45:20.435
clear, I have to say that the

00:45:20.459 --> 00:45:21.894
best course of action is to send

00:45:21.918 --> 00:45:24.101
that garment in for a ruling.

00:45:24.125 --> 00:45:25.643 position:20%
As I said, it's a simple

00:45:25.667 --> 00:45:27.059 position:20%
process, and in most cases,

00:45:27.083 --> 00:45:28.185
you'll have an answer in three

00:45:28.209 --> 00:45:30.810
days or even sooner than that.

00:45:30.834 --> 00:45:32.351
And maybe you'll help us add a

00:45:32.375 --> 00:45:33.976
new feature on to one of our

00:45:34.000 --> 00:45:35.226 position:20%
lists.

00:45:35.250 --> 00:45:38.393
Okay? So that is all I have

00:45:38.417 --> 00:45:39.852
for you for today other than

00:45:39.876 --> 00:45:42.059
listing my contact information,

00:45:42.083 --> 00:45:44.602
and I've also put up here on the

00:45:44.626 --> 00:45:46.351
contact information for my two

00:45:46.375 --> 00:45:52.059 position:20%
capable associates, Dianne

00:45:52.083 --> 00:45:56.143
Wickware and Ivory Wong. Any of

00:45:56.167 --> 00:45:57.101
us would be happy to help you

00:45:57.125 --> 00:45:58.976
out. So with that, I would like

00:45:59.000 --> 00:46:00.768
to turn it back over to Chrissi

00:46:00.792 --> 00:46:01.975 position:20%
and see if we have any

00:46:01.999 --> 00:46:06.975
questions. Chrissi, are you

00:46:06.999 --> 00:46:09.435
there, or am I just handling all

00:46:09.459 --> 00:46:19.226
of this? Okay. I'm going to

00:46:19.250 --> 00:46:20.476
just scroll to the top. Hello,

00:46:20.500 --> 00:46:22.560 position:20%
are you there?

00:46:22.584 --> 00:46:23.185
>> CHRISSI GUTH: Maryalice, we

00:46:23.209 --> 00:46:24.975 position:20%
do have some questions.

00:46:24.999 --> 00:46:25.727
>> MARYALICE NOWAK: Okay. I'm

00:46:25.751 --> 00:46:26.975
looking at the chat box now.

00:46:26.999 --> 00:46:27.685 position:20%
>> CHRISSI GUTH: Okay. I

00:46:27.709 --> 00:46:28.975
believe some of them you have

00:46:28.999 --> 00:46:30.810
answered. Someone asked what do

00:46:30.834 --> 00:46:32.727
you mean by light weight, and I

00:46:32.751 --> 00:46:34.435
believe on slide 17 you answer

00:46:34.459 --> 00:46:36.351 position:20%
that.

00:46:36.375 --> 00:46:37.185
>> MARYALICE NOWAK: Okay. Do

00:46:37.209 --> 00:46:38.101
you want me to go back to that

00:46:38.125 --> 00:46:43.975
one? Maybe that question was

00:46:43.999 --> 00:46:45.975 position:20%
asked before I got to that?

00:46:45.999 --> 00:46:46.975
>> CHRISSI GUTH: I believe so,

00:46:46.999 --> 00:46:48.018 position:20%
too.

00:46:48.042 --> 00:46:48.810 position:20%
>> MARYALICE NOWAK: Okay.

00:46:48.834 --> 00:46:51.975
Yeah. There is that ruling that

00:46:51.999 --> 00:46:56.101
951116 that explains our legal

00:46:56.125 --> 00:46:58.643
basis for using 200 grams per

00:46:58.667 --> 00:46:59.935
square meter. Hopefully that

00:46:59.959 --> 00:47:05.310 position:20%
answers your question.

00:47:05.334 --> 00:47:06.143
>> CHRISSI GUTH: Someone asked,

00:47:06.167 --> 00:47:07.435
on a webinar last year, there

00:47:07.459 --> 00:47:10.975 position:20%
was talk of a revised power

00:47:10.999 --> 00:47:12.560 position:20%
terminology. Is that still

00:47:12.584 --> 00:47:14.101
happening? And if so, when will

00:47:14.125 --> 00:47:16.476
the new apparel terminology --

00:47:16.500 --> 00:47:17.101
>> MARYALICE NOWAK: I believe

00:47:17.125 --> 00:47:18.435
it is still happening but it is

00:47:18.459 --> 00:47:19.560
out of our hands. I believe

00:47:19.584 --> 00:47:21.059
it's in the approval process and

00:47:21.083 --> 00:47:22.810 position:20%
I really haven't heard of a

00:47:22.834 --> 00:47:28.226
recent status update on that.

00:47:28.250 --> 00:47:28.975
>> CHRISSI GUTH: Okay. The

00:47:28.999 --> 00:47:30.852
other question would be graphic

00:47:30.876 --> 00:47:32.393
tees have traditionally been

00:47:32.417 --> 00:47:35.975
classified under 6110. Is this

00:47:35.999 --> 00:47:37.976 position:20%
still the case?

00:47:38.000 --> 00:47:38.810
>> MARYALICE NOWAK: I'm not

00:47:38.834 --> 00:47:40.476
sure which particular rulings

00:47:40.500 --> 00:47:43.310
you're referring to. Again, it

00:47:43.334 --> 00:47:44.727 position:20%
would be the method of

00:47:44.751 --> 00:47:47.268
decorating that garment, and

00:47:47.292 --> 00:47:48.101 position:20%
whether or not the method

00:47:48.125 --> 00:47:50.476
results in a raised surface on

00:47:50.500 --> 00:47:55.143 position:20%
the fabric.

00:47:55.167 --> 00:47:55.894 position:20%
>> CHRISSI GUTH: If the

00:47:55.918 --> 00:47:58.768 position:20%
long-sleeved T-shirts have

00:47:58.792 --> 00:48:01.101 position:20%
ribbed knit cuffs, finished

00:48:01.125 --> 00:48:03.894
sleeves versus hemmed sleeve, is

00:48:03.918 --> 00:48:07.810
this still similar to a T-shirt?

00:48:07.834 --> 00:48:08.393
>> MARYALICE NOWAK: At that

00:48:08.417 --> 00:48:12.226
point it doesn't matter. Rib

00:48:12.250 --> 00:48:15.975
knit ends on short sleeves are

00:48:15.999 --> 00:48:18.643
an inconspicuous non-T-shirt

00:48:18.667 --> 00:48:20.476 position:20%
feature. Long sleeves, no

00:48:20.500 --> 00:48:21.976
matter how they're finished, are

00:48:22.000 --> 00:48:24.435 position:20%
an inconspicuous T-shirt

00:48:24.459 --> 00:48:25.975
feature. We wouldn't double

00:48:25.999 --> 00:48:30.976
count if it's long sleeves and

00:48:31.000 --> 00:48:32.935
it really doesn't matter how

00:48:32.959 --> 00:48:34.602 position:20%
those ends are finished.

00:48:34.626 --> 00:48:35.602
>> CHRISSI GUTH: Is printing

00:48:35.626 --> 00:48:37.852
allowed, small spot print on

00:48:37.876 --> 00:48:40.560
front and big print on the back?

00:48:40.584 --> 00:48:41.143
>> MARYALICE NOWAK: Again, a

00:48:41.167 --> 00:48:43.351
garment could be printed all

00:48:43.375 --> 00:48:45.975
over, but the question is what

00:48:45.999 --> 00:48:47.518 position:20%
kind of printing is on that

00:48:47.542 --> 00:48:49.476
garment and does it result in a

00:48:49.500 --> 00:48:52.643 position:20%
raised surface.

00:48:52.667 --> 00:48:55.310
>> CHRISSI GUTH: Okay. Please

00:48:55.334 --> 00:48:56.975
explain why underwear type is

00:48:56.999 --> 00:49:01.975
always quoted. Outer wear type

00:49:01.999 --> 00:49:04.976 position:20%
can also fall under 6109?

00:49:05.000 --> 00:49:05.810
>> MARYALICE NOWAK: I don't

00:49:05.834 --> 00:49:07.727
understand the question. I'm

00:49:07.751 --> 00:49:09.810
looking at it, too, Fung, and I

00:49:09.834 --> 00:49:11.894
don't understand that question.

00:49:11.918 --> 00:49:15.226
If you're Shirley, can you maybe

00:49:15.250 --> 00:49:16.226
explain yourself in the chat

00:49:16.250 --> 00:49:17.852
box? We can move on and then

00:49:17.876 --> 00:49:19.975
we'll see if Shirley can provide

00:49:19.999 --> 00:49:21.852 position:20%
some clarification.

00:49:21.876 --> 00:49:23.975
>> Okay. So do you want me to

00:49:23.999 --> 00:49:24.975
continue reading rest of the

00:49:24.999 --> 00:49:25.935 position:20%
question?

00:49:25.959 --> 00:49:26.560
>> MARYALICE NOWAK: Sure. Why

00:49:26.584 --> 00:49:27.975
don't we do that. Yeah, why

00:49:27.999 --> 00:49:28.975 position:20%
don't we do that.

00:49:28.999 --> 00:49:29.727
>> FUNG KING KONG: Okay. What

00:49:29.751 --> 00:49:34.768
does small mean -- I believe she

00:49:34.792 --> 00:49:37.435 position:20%
meant what does small mean

00:49:37.459 --> 00:49:39.560 position:20%
measurement?

00:49:39.584 --> 00:49:40.143
>> MARYALICE NOWAK: I don't

00:49:40.167 --> 00:49:42.101
know what small mean is, though.

00:49:42.125 --> 00:49:43.351
>> FUNG KING KONG: Okay. Would

00:49:43.375 --> 00:49:46.059 position:20%
a T-shirt -- sorry.

00:49:46.083 --> 00:49:48.351 position:20%
>> MARYALICE NOWAK: Yeah,

00:49:48.375 --> 00:49:51.393 position:20%
Leslie, if you can provide

00:49:51.417 --> 00:49:52.226
clarification of what you're

00:49:52.250 --> 00:49:53.975
asking, we can circle back to

00:49:53.999 --> 00:49:54.310 position:20%
you.

00:49:54.334 --> 00:49:55.018 position:20%
>> FUNG KING KONG: With a

00:49:55.042 --> 00:49:56.975
T-shirt excluded from 6109 now

00:49:56.999 --> 00:49:59.476
be classified under 6105 since

00:49:59.500 --> 00:50:03.768
CBP changed last year that tops

00:50:03.792 --> 00:50:05.975 position:20%
should be -- should not be

00:50:05.999 --> 00:50:09.393
classified as 6110 unless there

00:50:09.417 --> 00:50:11.518 position:20%
are pockets at or below the

00:50:11.542 --> 00:50:13.976
waist or a tightening element?

00:50:14.000 --> 00:50:14.768 position:20%
>> MARYALICE NOWAK: Yeah.

00:50:14.792 --> 00:50:15.518
Yeah. You know what, this is

00:50:15.542 --> 00:50:16.894
going to -- this is kind of a

00:50:16.918 --> 00:50:17.975
little bit all over the place,

00:50:17.999 --> 00:50:21.852
but I don't -- you may be asking

00:50:21.876 --> 00:50:24.351
about women's garments because I

00:50:24.375 --> 00:50:30.268
know, like, the loose-fitting

00:50:30.292 --> 00:50:32.351
meant now that garments that

00:50:32.375 --> 00:50:33.602 position:20%
were formerly classified in

00:50:33.626 --> 00:50:36.101
6110, some of those are falling

00:50:36.125 --> 00:50:38.268 position:20%
I believe in 6106, but that

00:50:38.292 --> 00:50:40.602
doesn't affect men's garments.

00:50:40.626 --> 00:50:41.643 position:20%
I'm not sure if that's what

00:50:41.667 --> 00:50:42.975
you're asking. But there's no

00:50:42.999 --> 00:50:45.852 position:20%
loose-fitting retirement in

00:50:45.876 --> 00:50:51.351
men's garments in 6105, so --

00:50:51.375 --> 00:50:51.975 position:20%
>> FUNG KING KONG: Is

00:50:51.999 --> 00:50:53.935
single-knit jersey the same as

00:50:53.959 --> 00:50:55.310 position:20%
plain jersey?

00:50:55.334 --> 00:50:55.975
>> MARYALICE NOWAK: I'm not

00:50:55.999 --> 00:50:56.602 position:20%
sure what you mean by

00:50:56.626 --> 00:50:58.643
single-knit jersey, and it is a

00:50:58.667 --> 00:51:00.101
fabric question which I'm really

00:51:00.125 --> 00:51:01.976 position:20%
sort of precluded from

00:51:02.000 --> 00:51:06.975
responding to. I don't know if

00:51:06.999 --> 00:51:08.975 position:20%
single-knit jersey is a

00:51:08.999 --> 00:51:09.976 position:20%
technical term, so I would

00:51:10.000 --> 00:51:11.894
hesitate to weigh in on that.

00:51:11.918 --> 00:51:13.310 position:20%
That's outside my area of

00:51:13.334 --> 00:51:17.101 position:20%
responsibility.

00:51:17.125 --> 00:51:17.975
>> FUNG KING KONG: Thank you.

00:51:17.999 --> 00:51:19.852
The part of chapter 61 note 4

00:51:19.876 --> 00:51:22.351
that applies to garment without

00:51:22.375 --> 00:51:25.101
openings specify blouses, which

00:51:25.125 --> 00:51:27.435
are for women and girls. So

00:51:27.459 --> 00:51:28.976 position:20%
men's T-shirt can still be

00:51:29.000 --> 00:51:31.852 position:20%
classified in 6109?

00:51:31.876 --> 00:51:32.435 position:20%
>> MARYALICE NOWAK: Men's

00:51:32.459 --> 00:51:36.185
T-shirts are classified in 6109.

00:51:36.209 --> 00:51:38.101
I'm not -- again, if you have a

00:51:38.125 --> 00:51:39.310
follow-up question on that, I'm

00:51:39.334 --> 00:51:40.935
not sure I'm understanding that

00:51:40.959 --> 00:51:41.685 position:20%
properly.

00:51:41.709 --> 00:51:45.768
>> FUNG KING KONG: Okay. For

00:51:45.792 --> 00:51:47.810
apparel terminology, tank top

00:51:47.834 --> 00:51:49.810
sleeveless garments 6109, is

00:51:49.834 --> 00:51:52.768 position:20%
this no longer the case?

00:51:52.792 --> 00:51:53.976
>> MARYALICE NOWAK: Tank tops,

00:51:54.000 --> 00:51:56.975
you know, I don't get into those

00:51:56.999 --> 00:51:58.310
too much, you may be referring

00:51:58.334 --> 00:52:00.560
to women's garments. There are

00:52:00.584 --> 00:52:02.810
other breakouts in heading 6109.

00:52:02.834 --> 00:52:03.975 position:20%
Among them are thermal

00:52:03.999 --> 00:52:05.643
underwear. Again, I am not the

00:52:05.667 --> 00:52:08.975
underwear person. That's Karen

00:52:08.999 --> 00:52:11.975
Sikorsky. I was just drawing

00:52:11.999 --> 00:52:13.018
the distinction between T-shirts

00:52:13.042 --> 00:52:15.643
and that other provision at the

00:52:15.667 --> 00:52:17.768
subheading level, and those are

00:52:17.792 --> 00:52:20.435
the breakouts between T-shirts

00:52:20.459 --> 00:52:21.975
and then similar to a T-shirt.

00:52:21.999 --> 00:52:23.101
I'm not addressing the other

00:52:23.125 --> 00:52:24.393
subheadings within that heading

00:52:24.417 --> 00:52:28.393 position:20%
of 6109.

00:52:28.417 --> 00:52:29.018
>> FUNG KING KONG: Thank you.

00:52:29.042 --> 00:52:31.518
Does a T-shirt or other 6109

00:52:31.542 --> 00:52:34.351
must be tight-fitting, which

00:52:34.375 --> 00:52:38.476 position:20%
bumps it out of 6105?

00:52:38.500 --> 00:52:39.101
>> MARYALICE NOWAK: Again, if

00:52:39.125 --> 00:52:40.852
that is an issue, then that is

00:52:40.876 --> 00:52:43.643
an issue for women's garments

00:52:43.667 --> 00:52:45.935
and I can't comment on women's

00:52:45.959 --> 00:52:46.810 position:20%
garments.

00:52:46.834 --> 00:52:47.435
>> FUNG KING KONG: Okay. Thank

00:52:47.459 --> 00:52:48.852 position:20%
you. Would a garment with

00:52:48.876 --> 00:52:51.476
floral print on the front and no

00:52:51.500 --> 00:52:53.560
print on the back be excluded

00:52:53.584 --> 00:52:55.143 position:20%
from classification as a

00:52:55.167 --> 00:52:57.935 position:20%
T-shirt?

00:52:57.959 --> 00:52:58.852
>> MARYALICE NOWAK: No, not if

00:52:58.876 --> 00:53:00.101
it's -- like we talked about

00:53:00.125 --> 00:53:02.018
screen printing being flat on

00:53:02.042 --> 00:53:04.101
the garment. Let me go back to

00:53:04.125 --> 00:53:11.059
-- where is that? Like this

00:53:11.083 --> 00:53:12.476 position:20%
one. This black and white

00:53:12.500 --> 00:53:15.894
garment on the right. Can you

00:53:15.918 --> 00:53:17.975
all see that? If that was a

00:53:17.999 --> 00:53:19.975
floral print and it's just on

00:53:19.999 --> 00:53:21.476
the front, if it's screen print

00:53:21.500 --> 00:53:22.894
and it's flat on the garment,

00:53:22.918 --> 00:53:24.602
that's still acceptable for a

00:53:24.626 --> 00:53:29.059 position:20%
T-shirt.

00:53:29.083 --> 00:53:29.935
>> FUNG KING KONG: Maryalice,

00:53:29.959 --> 00:53:31.894
can you go to slide 43? This

00:53:31.918 --> 00:53:34.935 position:20%
question is for slide 43.

00:53:34.959 --> 00:53:37.476 position:20%
>> MARYALICE NOWAK: Okay.

00:53:37.500 --> 00:53:42.435 position:20%
How's that?

00:53:42.459 --> 00:53:42.976 position:20%
>> FUNG KING KONG: The red

00:53:43.000 --> 00:53:44.435
sleep an acceptable feature for

00:53:44.459 --> 00:53:46.643 position:20%
a T-shirt?

00:53:46.667 --> 00:53:47.268
>> MARYALICE NOWAK: Well, you

00:53:47.292 --> 00:53:48.393
know what, I was really trying

00:53:48.417 --> 00:53:50.226
to show you the large embroider

00:53:50.250 --> 00:53:53.393
y, but I think you can see that

00:53:53.417 --> 00:53:56.643
those are raglan sleeves, and as

00:53:56.667 --> 00:53:59.101
I mentioned, raglan sleeves are

00:53:59.125 --> 00:54:00.768 position:20%
an inconspicuous T-shirt

00:54:00.792 --> 00:54:02.268
feature. So if the garment had

00:54:02.292 --> 00:54:04.518
no other -- and I don't really

00:54:04.542 --> 00:54:05.768
know what the complete garment

00:54:05.792 --> 00:54:08.268
looked like, but do you remember

00:54:08.292 --> 00:54:13.018
these raglan sleeves here? If

00:54:13.042 --> 00:54:14.852 position:20%
that was the only feature,

00:54:14.876 --> 00:54:17.852
raglan sleeves are inconspicuous

00:54:17.876 --> 00:54:21.351
non-T-shirt feature. Hopefully

00:54:21.375 --> 00:54:25.727 position:20%
that answers that.

00:54:25.751 --> 00:54:26.268 position:20%
>> FUNG KING KONG: Someone

00:54:26.292 --> 00:54:27.560 position:20%
would like to see slide 40

00:54:27.584 --> 00:54:29.685 position:20%
again.

00:54:29.709 --> 00:54:30.310
>> MARYALICE NOWAK: Okay. I'm

00:54:30.334 --> 00:54:37.101 position:20%
right there.

00:54:37.125 --> 00:54:37.975
>> FUNG KING KONG: Okay. What

00:54:37.999 --> 00:54:40.976
would a similar to a T-shirt

00:54:41.000 --> 00:54:43.975
mean? Because some T-shirt with

00:54:43.999 --> 00:54:46.101
conspicuous non-T-shirt features

00:54:46.125 --> 00:54:50.643
fit there as a similar garment?

00:54:50.667 --> 00:54:51.226
>> MARYALICE NOWAK: I am not

00:54:51.250 --> 00:54:53.727
sure what that means. Similar

00:54:53.751 --> 00:54:56.268
to a T-shirt means it may have

00:54:56.292 --> 00:54:59.976
some inconspicuous non-T-shirt

00:55:00.000 --> 00:55:01.975 position:20%
features.

00:55:01.999 --> 00:55:02.894
>> FUNG KING KONG: Okay. Thank

00:55:02.918 --> 00:55:04.894
you. Is loose-fitting the same

00:55:04.918 --> 00:55:09.602 position:20%
as oversized?

00:55:09.626 --> 00:55:10.727
>> MARYALICE NOWAK: I really --

00:55:10.751 --> 00:55:11.975
you know, I can't comment on

00:55:11.999 --> 00:55:13.975
loose-fitting, because that is

00:55:13.999 --> 00:55:16.975
-- that is -- that's a women's

00:55:16.999 --> 00:55:19.852 position:20%
issue. But when I think of

00:55:19.876 --> 00:55:22.768
oversized, I'm thinking, you

00:55:22.792 --> 00:55:25.685 position:20%
know, those really big

00:55:25.709 --> 00:55:27.975
T-shirt-type garments that you

00:55:27.999 --> 00:55:30.518
might wear like at the beach, or

00:55:30.542 --> 00:55:33.226
as, you know -- I don't want to

00:55:33.250 --> 00:55:37.810
say pajamas, but -- like those

00:55:37.834 --> 00:55:38.852
really, you know, they might

00:55:38.876 --> 00:55:40.310
extend almost to your knees, and

00:55:40.334 --> 00:55:42.143 position:20%
oversized.

00:55:42.167 --> 00:55:42.975
>> FUNG KING KONG: Thank you.

00:55:42.999 --> 00:55:45.975
How do you determine if 6110, a

00:55:45.999 --> 00:55:48.643
non-T-shirt is not a blouse,

00:55:48.667 --> 00:55:50.975
which is under the new tariff

00:55:50.999 --> 00:55:52.310 position:20%
change?

00:55:52.334 --> 00:55:52.975
>> MARYALICE NOWAK: I can't

00:55:52.999 --> 00:55:54.310 position:20%
address blouses. Those are

00:55:54.334 --> 00:55:56.975 position:20%
women's garments.

00:55:56.999 --> 00:55:57.643
>> FUNG KING KONG: Thank you.

00:55:57.667 --> 00:56:01.101
Why is underwear type is always

00:56:01.125 --> 00:56:05.935
quoted. Outer wear type can

00:56:05.959 --> 00:56:07.975
also fall under 6109? I think

00:56:07.999 --> 00:56:08.976 position:20%
Shirley just retyped her

00:56:09.000 --> 00:56:10.518 position:20%
question again.

00:56:10.542 --> 00:56:11.101
>> MARYALICE NOWAK: I don't

00:56:11.125 --> 00:56:13.059 position:20%
understand what you mean by

00:56:13.083 --> 00:56:21.018
underwear type always quoted.

00:56:21.042 --> 00:56:22.310
>> FUNG KING KONG: If a knit

00:56:22.334 --> 00:56:25.727 position:20%
T-shirt/top has a ribbed

00:56:25.751 --> 00:56:26.852 position:20%
waistband, would it be

00:56:26.876 --> 00:56:32.351
classified under 6110 or 6114?

00:56:32.375 --> 00:56:32.975
>> MARYALICE NOWAK: I would

00:56:32.999 --> 00:56:33.685 position:20%
have to see the complete

00:56:33.709 --> 00:56:36.975
garment. I can tell you that it

00:56:36.999 --> 00:56:40.643
would not be classified in 6109.

00:56:40.667 --> 00:56:41.975
But that alone is not enough

00:56:41.999 --> 00:56:44.185 position:20%
information to provide a

00:56:44.209 --> 00:56:50.018 position:20%
definitive classification.

00:56:50.042 --> 00:56:51.560
>> FUNG KING KONG: James asks

00:56:51.584 --> 00:56:53.518
why would the sleeveless T-shirt

00:56:53.542 --> 00:56:55.143
shown not be classified as a

00:56:55.167 --> 00:56:59.101 position:20%
tank top?

00:56:59.125 --> 00:56:59.935
>> MARYALICE NOWAK: Again, I

00:56:59.959 --> 00:57:01.976
really -- I don't handle tank

00:57:02.000 --> 00:57:04.351 position:20%
tops. Those are normally

00:57:04.375 --> 00:57:07.185
women's garments. Muscle shirts

00:57:07.209 --> 00:57:08.976 position:20%
are 6110. I think it has

00:57:09.000 --> 00:57:12.975
something to do probably with

00:57:12.999 --> 00:57:14.435 position:20%
where the back of the shirt

00:57:14.459 --> 00:57:15.602
falls with respect to the nape

00:57:15.626 --> 00:57:21.643
of the neck. I believe the back

00:57:21.667 --> 00:57:23.393 position:20%
of that garment would most

00:57:23.417 --> 00:57:25.476
likely be, you know, the same --

00:57:25.500 --> 00:57:27.059
like it would fall on the same

00:57:27.083 --> 00:57:29.518
part of the body as a T-shirt,

00:57:29.542 --> 00:57:30.685
but the only difference being

00:57:30.709 --> 00:57:33.059
there are no sleeves. T-shirts

00:57:33.083 --> 00:57:35.143
-- or tank tops have, I believe,

00:57:35.167 --> 00:57:36.685
pretty specific requirements,

00:57:36.709 --> 00:57:40.852
like the shoulders can't be --

00:57:40.876 --> 00:57:42.643
Fung, do you know this offhand?

00:57:42.667 --> 00:57:44.518
Are they two and a half inches

00:57:44.542 --> 00:57:47.810 position:20%
in width?

00:57:47.834 --> 00:57:48.435
>> FUNG KING KONG: But that's

00:57:48.459 --> 00:57:49.975
for women, so I'm not a hundred

00:57:49.999 --> 00:57:51.059 position:20%
percent sure.

00:57:51.083 --> 00:57:51.852 position:20%
>> MARYALICE NOWAK: Again,

00:57:51.876 --> 00:57:53.059
again, yeah, but just because it

00:57:53.083 --> 00:57:55.518
doesn't have sleeves doesn't

00:57:55.542 --> 00:57:56.351
necessarily mean that it's a

00:57:56.375 --> 00:57:57.685 position:20%
tank top by definition.

00:57:57.709 --> 00:57:58.310
>> FUNG KING KONG: Okay. Does

00:57:58.334 --> 00:57:59.975
T-shirt length change from 6109

00:57:59.999 --> 00:58:04.435
to 6110? For example, a tunic

00:58:04.459 --> 00:58:06.101 position:20%
tee?

00:58:06.125 --> 00:58:06.852 position:20%
>> MARYALICE NOWAK: Does

00:58:06.876 --> 00:58:11.976
T-shirt length change? I don't

00:58:12.000 --> 00:58:15.518 position:20%
know what a tunic tee is.

00:58:15.542 --> 00:58:16.143
>> FUNG KING KONG: What if the

00:58:16.167 --> 00:58:19.727 position:20%
T-shirt has a zipper?

00:58:19.751 --> 00:58:21.351
>> MARYALICE NOWAK: No. No

00:58:21.375 --> 00:58:22.975
fastenings. Again, is there a

00:58:22.999 --> 00:58:27.518 position:20%
zipper on underwear? No.

00:58:27.542 --> 00:58:28.018 position:20%
>> FUNG KING KONG: For

00:58:28.042 --> 00:58:29.975 position:20%
sleeveless shirt, if the

00:58:29.999 --> 00:58:33.101
shoulder strap is not over two

00:58:33.125 --> 00:58:34.685
inches, belonging to heading

00:58:34.709 --> 00:58:36.935
6109, if over two inches, it

00:58:36.959 --> 00:58:39.435 position:20%
belongs to 6110?

00:58:39.459 --> 00:58:40.059
>> MARYALICE NOWAK: Right. Is

00:58:40.083 --> 00:58:42.643
there -- yeah. Now we're doing

00:58:42.667 --> 00:58:44.226
tank tops, which is outside the

00:58:44.250 --> 00:58:48.435 position:20%
scope of this discussion.

00:58:48.459 --> 00:58:48.975 position:20%
>> FUNG KING KONG: For

00:58:48.999 --> 00:58:50.643 position:20%
sleeveless shirts, if the

00:58:50.667 --> 00:58:52.518
shoulder strap is not over two

00:58:52.542 --> 00:58:54.643
inches -- oh, it's a repeat of

00:58:54.667 --> 00:58:55.768 position:20%
the same question. Sorry.

00:58:55.792 --> 00:58:56.310 position:20%
>> MARYALICE NOWAK: Yeah.

00:58:56.334 --> 00:58:59.268 position:20%
Yeah. No, that's okay.

00:58:59.292 --> 00:58:59.975 position:20%
>> FUNG KING KONG: Would a

00:58:59.999 --> 00:59:01.351
garment that is cotton in the

00:59:01.375 --> 00:59:04.518
front and polyester in the back

00:59:04.542 --> 00:59:05.643 position:20%
be considered piece

00:59:05.667 --> 00:59:06.268 position:20%
construction, and therefore

00:59:06.292 --> 00:59:07.975
excluded from classification

00:59:07.999 --> 00:59:10.975 position:20%
under 6109?

00:59:10.999 --> 00:59:11.727
>> MARYALICE NOWAK: You know,

00:59:11.751 --> 00:59:12.268 position:20%
that's a really interesting

00:59:12.292 --> 00:59:13.602
question, I don't think I've

00:59:13.626 --> 00:59:15.476
ever seen a garment like that.

00:59:15.500 --> 00:59:16.768 position:20%
But again, you can have a

00:59:16.792 --> 00:59:18.518
T-shirt that's constructed with

00:59:18.542 --> 00:59:19.976
one front panel and one back

00:59:20.000 --> 00:59:22.975
panel. If they're different,

00:59:22.999 --> 00:59:24.976
you know what, I would have to

00:59:25.000 --> 00:59:27.143 position:20%
take a look at that.

00:59:27.167 --> 00:59:27.975
>> FUNG KING KONG: Is there an

00:59:27.999 --> 00:59:29.518 position:20%
acceptable size limit to a

00:59:29.542 --> 00:59:32.975 position:20%
pocket on a T-shirt?

00:59:32.999 --> 00:59:33.602
>> MARYALICE NOWAK: No. There

00:59:33.626 --> 00:59:35.143
is nothing -- you know, when I

00:59:35.167 --> 00:59:37.727
start, you know, talking about

00:59:37.751 --> 00:59:39.976
size, like even sizes like small

00:59:40.000 --> 00:59:41.935
heat seals, large heat seals,

00:59:41.959 --> 00:59:43.310
there is nothing that's cast in

00:59:43.334 --> 00:59:46.975
stone on any of those things,

00:59:46.999 --> 00:59:49.727 position:20%
but I think everyone can

00:59:49.751 --> 00:59:52.101
hopefully envision when I say a

00:59:52.125 --> 00:59:54.101
single, plain chest pocket on a

00:59:54.125 --> 00:59:56.975
T-shirt, you've got an idea in

00:59:56.999 --> 00:59:58.685
your head. You've seen those

00:59:58.709 --> 01:00:01.393
garments. Those are acceptable.

01:00:01.417 --> 01:00:03.852
Is there a limit? No, there's

01:00:03.876 --> 01:00:06.476
no numerical, you know, size

01:00:06.500 --> 01:00:07.976 position:20%
limit that's cast in stone.

01:00:08.000 --> 01:00:09.602
>> FUNG KING KONG: Thank you.

01:00:09.626 --> 01:00:10.768
There's two people that would

01:00:10.792 --> 01:00:15.852
like to see slide 32, 41, 42 and

01:00:15.876 --> 01:00:17.185 position:20%
43.

01:00:17.209 --> 01:00:17.975 position:20%
>> MARYALICE NOWAK: Okay.

01:00:17.999 --> 01:00:21.643 position:20%
Let's do 32 first. Okay.

01:00:21.667 --> 01:00:23.018
>> FUNG KING KONG: Okay. Maybe

01:00:23.042 --> 01:00:24.975
give it a second. And then I

01:00:24.999 --> 01:00:26.518 position:20%
could give you a question?

01:00:26.542 --> 01:00:27.393 position:20%
>> MARYALICE NOWAK: Okay.

01:00:27.417 --> 01:00:27.976
>> FUNG KING KONG: There was

01:00:28.000 --> 01:00:32.435
mention that oversized with full

01:00:32.459 --> 01:00:35.143 position:20%
unconspicuous. What is the

01:00:35.167 --> 01:00:36.975 position:20%
definition of oversize?

01:00:36.999 --> 01:00:37.727 position:20%
>> MARYALICE NOWAK: There

01:00:37.751 --> 01:00:38.518
really is no definition. You

01:00:38.542 --> 01:00:40.351
know, what we would do is put it

01:00:40.375 --> 01:00:41.975 position:20%
on an appropriate-sized

01:00:41.999 --> 01:00:44.059
mannequin or form in our office,

01:00:44.083 --> 01:00:45.975 position:20%
take a look at how it lays.

01:00:45.999 --> 01:00:48.768
Again, you know, oversized, it's

01:00:48.792 --> 01:00:50.351
a subjective term. It's like

01:00:50.375 --> 01:00:52.602
small and large, right? So we

01:00:52.626 --> 01:00:55.101 position:20%
will see, you know, how it

01:00:55.125 --> 01:00:57.975 position:20%
falls.

01:00:57.999 --> 01:00:59.476
What was the next slide after

01:00:59.500 --> 01:01:01.018
32, Fung, that they wanted to

01:01:01.042 --> 01:01:02.018 position:20%
see?

01:01:02.042 --> 01:01:03.351
>> FUNG KING KONG: 41, 42 and

01:01:03.375 --> 01:01:05.476 position:20%
43.

01:01:05.500 --> 01:01:06.894
>> MARYALICE NOWAK: Okay. 41.

01:01:06.918 --> 01:01:07.518
>> FUNG KING KONG: Okay. And

01:01:07.542 --> 01:01:08.975
then let me give you another

01:01:08.999 --> 01:01:11.185
question, so whoever wants this

01:01:11.209 --> 01:01:13.975
slide can take a look at it.

01:01:13.999 --> 01:01:15.810
How do you decipher what is an

01:01:15.834 --> 01:01:18.059
oversized T-shirt and what is

01:01:18.083 --> 01:01:21.476 position:20%
loose-fit T-shirt?

01:01:21.500 --> 01:01:22.018 position:20%
>> MARYALICE NOWAK: Okay.

01:01:22.042 --> 01:01:24.476
Again, I'm not going to address

01:01:24.500 --> 01:01:25.518 position:20%
loose-fitting because

01:01:25.542 --> 01:01:26.975 position:20%
loose-fitting, it's in the

01:01:26.999 --> 01:01:28.602
chapter note for blouses, and

01:01:28.626 --> 01:01:30.976
blouses are women's garments.

01:01:31.000 --> 01:01:31.768 position:20%
>> FUNG KING KONG: Will a

01:01:31.792 --> 01:01:33.727
non-raised graphic tee now go

01:01:33.751 --> 01:01:37.476 position:20%
under 6109, other T-shirt,

01:01:37.500 --> 01:01:39.975 position:20%
regardless of graphic size?

01:01:39.999 --> 01:01:40.768
>> MARYALICE NOWAK: The size

01:01:40.792 --> 01:01:43.476
does not matter. I think we may

01:01:43.500 --> 01:01:44.602
have had this question in some

01:01:44.626 --> 01:01:46.975
form a little earlier on today.

01:01:46.999 --> 01:01:50.810
The idea is that the design does

01:01:50.834 --> 01:01:52.975
not result in a raised surface

01:01:52.999 --> 01:01:54.894
on the fabric. It's not the

01:01:54.918 --> 01:01:59.101 position:20%
size of the graphic per se.

01:01:59.125 --> 01:02:00.975
>> FUNG KING KONG: Thank you.

01:02:00.999 --> 01:02:02.768
Sorry. What is the difference

01:02:02.792 --> 01:02:11.226
between -- from 6109.10.0018,

01:02:11.250 --> 01:02:20.810 position:20%
versus 6100.009.

01:02:20.834 --> 01:02:21.393
>> MARYALICE NOWAK: I don't

01:02:21.417 --> 01:02:27.975
know. Let me just open up my

01:02:27.999 --> 01:02:29.685
folder old school so I have it

01:02:29.709 --> 01:02:33.935 position:20%
here. What was it?

01:02:33.959 --> 01:02:37.101
>> FUNG KING KONG: 0018 versus

01:02:37.125 --> 01:02:42.018 position:20%
6109.10.0027.

01:02:42.042 --> 01:02:42.894
>> MARYALICE NOWAK: Okay. 18

01:02:42.918 --> 01:02:46.685
is a tank top. And 27 is those

01:02:46.709 --> 01:02:47.518 position:20%
other garments that I was

01:02:47.542 --> 01:02:48.393
talking about that are similar

01:02:48.417 --> 01:02:50.975 position:20%
to T-shirts.

01:02:50.999 --> 01:02:52.975
>> FUNG KING KONG: Thank you.

01:02:52.999 --> 01:02:55.852
Can a graphic T-shirt with a

01:02:55.876 --> 01:02:59.975
flat print logo be under 6110 --

01:02:59.999 --> 01:03:04.185
I mean, sorry, 6109.10.0012?

01:03:04.209 --> 01:03:04.975
>> MARYALICE NOWAK: I'm sorry.

01:03:04.999 --> 01:03:06.852
Can you say that again, Fung?

01:03:06.876 --> 01:03:07.351 position:20%
>> FUNG KING KONG: Can a

01:03:07.375 --> 01:03:09.727 position:20%
graphic T-shirt with a flat

01:03:09.751 --> 01:03:11.059 position:20%
print logo be under

01:03:11.083 --> 01:03:17.894 position:20%
6109.10.0012?

01:03:17.918 --> 01:03:19.975
>> MARYALICE NOWAK: 100012, if

01:03:19.999 --> 01:03:20.975
there is nothing that takes it

01:03:20.999 --> 01:03:22.226
out of a T-shirt classification,

01:03:22.250 --> 01:03:24.268
I'd say it's entirely possible.

01:03:24.292 --> 01:03:27.975 position:20%
Without seeing it.

01:03:27.999 --> 01:03:28.768
>> FUNG KING KONG: Thank you.

01:03:28.792 --> 01:03:31.435
Many T-shirts are not underwear

01:03:31.459 --> 01:03:32.976
type. Can they still fall under

01:03:33.000 --> 01:03:35.351 position:20%
6109?

01:03:35.375 --> 01:03:35.975 position:20%
>> MARYALICE NOWAK: Yes.

01:03:35.999 --> 01:03:39.476
T-shirts that -- 6109 covers

01:03:39.500 --> 01:03:42.018
T-shirts that are underwear that

01:03:42.042 --> 01:03:43.226
when -- that particular kind of

01:03:43.250 --> 01:03:44.435
underwear that we talked about,

01:03:44.459 --> 01:03:48.975
that 6109.10.0004, and T-shirts

01:03:48.999 --> 01:03:51.975
that are worn at outer-wear type

01:03:51.999 --> 01:03:54.226 position:20%
garments, yes.

01:03:54.250 --> 01:03:54.975
>> FUNG KING KONG: Generally,

01:03:54.999 --> 01:03:58.643 position:20%
loose with ripped cuffs or

01:03:58.667 --> 01:04:00.185 position:20%
looser fitting, do the long

01:04:00.209 --> 01:04:03.476
sleeve have to be close fitting?

01:04:03.500 --> 01:04:05.143
>> MARYALICE NOWAK: Yeah. They

01:04:05.167 --> 01:04:07.727
have to be close-fitting. I

01:04:07.751 --> 01:04:14.975
think I showed you -- do you see

01:04:14.999 --> 01:04:19.143 position:20%
that long, close-fitting

01:04:19.167 --> 01:04:22.185 position:20%
sleeves?

01:04:22.209 --> 01:04:23.351
Again, that's the kind of thing

01:04:23.375 --> 01:04:24.852
you've got a garment like that,

01:04:24.876 --> 01:04:26.643
we would need to just put it on

01:04:26.667 --> 01:04:28.727
the form and see how it falls.

01:04:28.751 --> 01:04:31.059
I'm not -- I'm honestly not too

01:04:31.083 --> 01:04:32.976 position:20%
familiar with long,

01:04:33.000 --> 01:04:34.435
loose-fitting sleeves. I think

01:04:34.459 --> 01:04:40.768 position:20%
those are more rare.

01:04:40.792 --> 01:04:41.518
>> FUNG KING KONG: Is there a

01:04:41.542 --> 01:04:45.976 position:20%
length requirement? Crop

01:04:46.000 --> 01:04:48.975 position:20%
T-shirt are common now.

01:04:48.999 --> 01:04:49.768
>> MARYALICE NOWAK: I'm sorry.

01:04:49.792 --> 01:04:50.768
Can you say that again? I'm

01:04:50.792 --> 01:04:51.894
trying to follow along with you,

01:04:51.918 --> 01:04:53.935
too, Fung, and I don't see that

01:04:53.959 --> 01:04:54.560 position:20%
question.

01:04:54.584 --> 01:04:55.185
>> FUNG KING KONG: Sorry. It's

01:04:55.209 --> 01:04:57.975 position:20%
from Cecilia. She asked a

01:04:57.999 --> 01:05:00.393
length requirement, crop T-shirt

01:05:00.417 --> 01:05:02.727
are common now, T-shirt 0 top.

01:05:02.751 --> 01:05:03.351
>> MARYALICE NOWAK: I will tell

01:05:03.375 --> 01:05:05.059
you that if it doesn't reach to

01:05:05.083 --> 01:05:06.476
the waist, it's not going to be

01:05:06.500 --> 01:05:10.727
6109. It will most likely be in

01:05:10.751 --> 01:05:13.768
6114 because it does not provide

01:05:13.792 --> 01:05:16.226
adequate coverage. But I would

01:05:16.250 --> 01:05:17.393 position:20%
prefer to see that garment

01:05:17.417 --> 01:05:20.685
before I would go on record with

01:05:20.709 --> 01:05:22.976 position:20%
that.

01:05:23.000 --> 01:05:23.852
>> FUNG KING KONG: So you have

01:05:23.876 --> 01:05:25.393
pictures of different kinds of

01:05:25.417 --> 01:05:26.976 position:20%
T-shirt with classification

01:05:27.000 --> 01:05:30.310
number next to it for reference?

01:05:30.334 --> 01:05:30.975
>> MARYALICE NOWAK: No, I do

01:05:30.999 --> 01:05:32.894
not. No, I tried to show you

01:05:32.918 --> 01:05:33.975
the different kind of features

01:05:33.999 --> 01:05:35.268
and the kinds of reasoning that

01:05:35.292 --> 01:05:39.727
I go through, but I am not going

01:05:39.751 --> 01:05:42.975 position:20%
to -- I can't provide just

01:05:42.999 --> 01:05:44.185
pictures with classifications of

01:05:44.209 --> 01:05:44.976
the garment. There could be

01:05:45.000 --> 01:05:46.018
other features of the garment

01:05:46.042 --> 01:05:47.143 position:20%
that would change the

01:05:47.167 --> 01:05:52.976 position:20%
classification.

01:05:53.000 --> 01:05:53.852
>> FUNG KING KONG: Thank you.

01:05:53.876 --> 01:05:54.476
Many times you have quoted that

01:05:54.500 --> 01:05:56.185 position:20%
the T-shirt under 6109 or

01:05:56.209 --> 01:05:58.975
underwear type, many T-shirt are

01:05:58.999 --> 01:06:01.351 position:20%
not worn as underwear type.

01:06:01.375 --> 01:06:04.852
6109 can also be T-shirt that

01:06:04.876 --> 01:06:06.518 position:20%
are worn with jeans, for

01:06:06.542 --> 01:06:07.976
example, which are not underwear

01:06:08.000 --> 01:06:11.975 position:20%
type.

01:06:11.999 --> 01:06:12.643 position:20%
>> MARYALICE NOWAK: You're

01:06:12.667 --> 01:06:15.018
correct. Yeah. 6109 covers

01:06:15.042 --> 01:06:16.560 position:20%
T-shirts that are truly

01:06:16.584 --> 01:06:21.185
underwear and T-shirts that are

01:06:21.209 --> 01:06:22.976
worn as conventional attire.

01:06:23.000 --> 01:06:24.975 position:20%
Underwear type doesn't mean

01:06:24.999 --> 01:06:26.268
garment, or doesn't mean actual

01:06:26.292 --> 01:06:28.476
underwear. It means you look at

01:06:28.500 --> 01:06:30.435 position:20%
the garment and its basic

01:06:30.459 --> 01:06:31.935
character and appearance is that

01:06:31.959 --> 01:06:32.976 position:20%
of underwear, and there's

01:06:33.000 --> 01:06:34.226
nothing like we talked about.

01:06:34.250 --> 01:06:36.518
So especially those conspicuous

01:06:36.542 --> 01:06:38.852 position:20%
features that would be so

01:06:38.876 --> 01:06:39.935
inconsistent with underwear that

01:06:39.959 --> 01:06:40.975
it, you know, excludes it from

01:06:40.999 --> 01:06:44.975 position:20%
the heading entirely. But

01:06:44.999 --> 01:06:47.975 position:20%
T-shirts also cover, quote

01:06:47.999 --> 01:06:50.727
unquote, outer wear garments

01:06:50.751 --> 01:06:51.975
conventional attire, and not

01:06:51.999 --> 01:06:53.810 position:20%
just underwear.

01:06:53.834 --> 01:06:54.975
>> FUNG KING KONG: Thank you.

01:06:54.999 --> 01:06:57.976
Would a T-shirt with one or two

01:06:58.000 --> 01:06:59.685 position:20%
buttons by the neckline be

01:06:59.709 --> 01:07:00.975
classified as T-shirt or other

01:07:00.999 --> 01:07:04.101 position:20%
similar?

01:07:04.125 --> 01:07:04.975
>> MARYALICE NOWAK: It wouldn't

01:07:04.999 --> 01:07:08.894
be classified in 6109 at all.

01:07:08.918 --> 01:07:10.310
Buttons. T-shirts do not have

01:07:10.334 --> 01:07:12.101
buttons or other fastenings, and

01:07:12.125 --> 01:07:13.351 position:20%
I think I showed you the

01:07:13.375 --> 01:07:14.768
explanatory note and the ICP

01:07:14.792 --> 01:07:18.101 position:20%
entry for both of those.

01:07:18.125 --> 01:07:19.935
>> FUNG KING KONG: Thank you.

01:07:19.959 --> 01:07:22.975
Slub knit jersey fabric is not

01:07:22.999 --> 01:07:24.768 position:20%
classified as a T-shirt but

01:07:24.792 --> 01:07:25.727
would it be considered similar

01:07:25.751 --> 01:07:28.268 position:20%
to a T-shirt?

01:07:28.292 --> 01:07:28.975
>> MARYALICE NOWAK: If it is

01:07:28.999 --> 01:07:30.810 position:20%
not plain jersey or plain

01:07:30.834 --> 01:07:31.975 position:20%
interlock, it is not

01:07:31.999 --> 01:07:38.268 position:20%
classifiable in 6109.

01:07:38.292 --> 01:07:38.975
>> FUNG KING KONG: As we are

01:07:38.999 --> 01:07:40.059 position:20%
talking about printed tees,

01:07:40.083 --> 01:07:42.727
would it make a difference in

01:07:42.751 --> 01:07:45.268
term of classification if the

01:07:45.292 --> 01:07:47.685
consumer printed the tee or the

01:07:47.709 --> 01:07:50.059
tee was printed elsewhere, like

01:07:50.083 --> 01:07:53.602 position:20%
a third party?

01:07:53.626 --> 01:07:54.226
>> MARYALICE NOWAK: I'm not

01:07:54.250 --> 01:07:57.018
sure what that means. If the

01:07:57.042 --> 01:07:58.435
consumer printed the tee, you

01:07:58.459 --> 01:08:05.268
mean like after purchasing it?

01:08:05.292 --> 01:08:07.268
Andrew, can you maybe clarify

01:08:07.292 --> 01:08:14.059 position:20%
that? Thank you.

01:08:14.083 --> 01:08:14.935
>> FUNG KING KONG: Thank you.

01:08:14.959 --> 01:08:15.727
Someone would like for you to

01:08:15.751 --> 01:08:16.975
explain the meaning of all the

01:08:16.999 --> 01:08:20.143
ten digit in the tariff code.

01:08:20.167 --> 01:08:21.727
>> MARYALICE NOWAK: All the ten

01:08:21.751 --> 01:08:22.975
digits? Well, actually, the

01:08:22.999 --> 01:08:25.560
harmonized tariff schedule, that

01:08:25.584 --> 01:08:31.393
is just our international method

01:08:31.417 --> 01:08:33.975
for worldwide trade. So when we

01:08:33.999 --> 01:08:38.975
say harmonized, what we mean is

01:08:38.999 --> 01:08:40.185
that every country that uses

01:08:40.209 --> 01:08:41.975
this tariff schedule to classify

01:08:41.999 --> 01:08:45.435
their goods to engage in customs

01:08:45.459 --> 01:08:47.101 position:20%
activities, importing and

01:08:47.125 --> 01:08:48.185 position:20%
exporting, those first six

01:08:48.209 --> 01:08:51.852
numbers should be harmonized or

01:08:51.876 --> 01:08:53.393
the same among all countries.

01:08:53.417 --> 01:08:54.143 position:20%
Now, sometimes there's

01:08:54.167 --> 01:08:55.727
differences of opinion, but in

01:08:55.751 --> 01:08:58.975
general. 6109.10 is going to be

01:08:58.999 --> 01:08:59.975
the same in the United States

01:08:59.999 --> 01:09:01.476
versus Canada, versus China,

01:09:01.500 --> 01:09:02.602 position:20%
versus anywhere.

01:09:02.626 --> 01:09:04.310
When you get into the seventh

01:09:04.334 --> 01:09:06.435
and eighth and then the ninth

01:09:06.459 --> 01:09:08.852 position:20%
and tenth digits, those are

01:09:08.876 --> 01:09:10.518
specific -- the ones you see in

01:09:10.542 --> 01:09:11.975
the harmonized tariff schedule,

01:09:11.999 --> 01:09:12.975
the United States, those are

01:09:12.999 --> 01:09:16.435
specific to U.S. imports. Okay?

01:09:16.459 --> 01:09:18.643
That just -- we have breakouts

01:09:18.667 --> 01:09:20.310 position:20%
in our tariff schedule that

01:09:20.334 --> 01:09:23.518 position:20%
other countries don't have

01:09:23.542 --> 01:09:24.935 position:20%
because there's additional

01:09:24.959 --> 01:09:25.894 position:20%
information we want to know

01:09:25.918 --> 01:09:27.727
about those imports that other

01:09:27.751 --> 01:09:29.393
countries have indicated they

01:09:29.417 --> 01:09:31.643
don't care as much about. The

01:09:31.667 --> 01:09:33.518 position:20%
ninth and tenth digits are

01:09:33.542 --> 01:09:37.975
statistical. That's really --

01:09:37.999 --> 01:09:39.143
that's really the purpose of

01:09:39.167 --> 01:09:40.226
those ten digits. I don't know

01:09:40.250 --> 01:09:42.975
if that answers your question.

01:09:42.999 --> 01:09:43.685
>> FUNG KING KONG: Thank you.

01:09:43.709 --> 01:09:44.975
Someone would like to see slide

01:09:44.999 --> 01:09:54.226
29 again. Okay. Thank you.

01:09:54.250 --> 01:09:56.310
What is the definition of long

01:09:56.334 --> 01:09:59.935
sleeve? Does this mean to the

01:09:59.959 --> 01:10:02.101
wrist? And does short sleeve

01:10:02.125 --> 01:10:03.935 position:20%
mean above the elbows?

01:10:03.959 --> 01:10:04.975
Therefore, any sleeve between

01:10:04.999 --> 01:10:07.310
the elbow and wrist would fall

01:10:07.334 --> 01:10:10.351 position:20%
under other similar?

01:10:10.375 --> 01:10:10.975
>> MARYALICE NOWAK: You know

01:10:10.999 --> 01:10:11.975
what, that is such a specific

01:10:11.999 --> 01:10:13.768
question, I would want to see

01:10:13.792 --> 01:10:15.393 position:20%
the garment. Long sleeves

01:10:15.417 --> 01:10:16.975
generally means to the wrist.

01:10:16.999 --> 01:10:19.602
Short sleeve is generally what

01:10:19.626 --> 01:10:21.226
you think of as a short-sleeved

01:10:21.250 --> 01:10:23.018 position:20%
garment. I think I did go

01:10:23.042 --> 01:10:28.518
through pretty much everything

01:10:28.542 --> 01:10:32.310
in between, like we go -- where

01:10:32.334 --> 01:10:35.975 position:20%
is it? Here it is. Elbow

01:10:35.999 --> 01:10:38.975
length, three-quarter, you know,

01:10:38.999 --> 01:10:40.435 position:20%
those are going to be

01:10:40.459 --> 01:10:41.435 position:20%
conspicuous non-T-shirt

01:10:41.459 --> 01:10:45.975 position:20%
features.

01:10:45.999 --> 01:10:49.351
>> FUNG KING KONG: Thank you.

01:10:49.375 --> 01:10:50.768
Wouldn't underwear type be the

01:10:50.792 --> 01:10:53.810
type of T-shirt that a man --

01:10:53.834 --> 01:10:55.810
that a man wears underneath his

01:10:55.834 --> 01:10:57.935 position:20%
dress shirt?

01:10:57.959 --> 01:10:58.560
>> MARYALICE NOWAK: That's the

01:10:58.584 --> 01:10:59.143
kind of thing you're thinking

01:10:59.167 --> 01:11:01.975 position:20%
about, yeah. Underwear.

01:11:01.999 --> 01:11:20.975
T-shirts that are underwear.

01:11:20.999 --> 01:11:21.560
>> FUNG KING KONG: Tank tops

01:11:21.584 --> 01:11:25.143
have requirement for the strap

01:11:25.167 --> 01:11:26.435
width? I think you answered

01:11:26.459 --> 01:11:27.727 position:20%
that already.

01:11:27.751 --> 01:11:32.643
>> MARYALICE NOWAK: Yes, I did.

01:11:32.667 --> 01:11:33.226
>> FUNG KING KONG: Ribbed or

01:11:33.250 --> 01:11:35.810
overfabric have a regular hem.

01:11:35.834 --> 01:11:37.602 position:20%
Is this a rib waist?

01:11:37.626 --> 01:11:38.185
>> MARYALICE NOWAK: I don't

01:11:38.209 --> 01:11:38.975 position:20%
know what that means. I'm

01:11:38.999 --> 01:11:39.975 position:20%
sorry.

01:11:39.999 --> 01:11:41.975
>> FUNG KING KONG: Okay. The

01:11:41.999 --> 01:11:44.975
word "oversize" means that the

01:11:44.999 --> 01:11:47.351
cut just that, oversized, the

01:11:47.375 --> 01:11:48.768
garment will not give that loose

01:11:48.792 --> 01:11:54.894
look. Loose fit or relaxed fit,

01:11:54.918 --> 01:12:06.643 position:20%
that's the difference.

01:12:06.667 --> 01:12:07.975 position:20%
Okay. Once a garment is

01:12:07.999 --> 01:12:10.185
excluded from classification

01:12:10.209 --> 01:12:13.975
under 6109 due to a conspicuous

01:12:13.999 --> 01:12:15.476 position:20%
feature, would it then be

01:12:15.500 --> 01:12:17.768 position:20%
classified under 6110 as a

01:12:17.792 --> 01:12:20.975
pullover, or do we need to first

01:12:20.999 --> 01:12:22.351
consider classification under

01:12:22.375 --> 01:12:34.643 position:20%
6110 as a sweater?

01:12:34.667 --> 01:12:36.435
>> MARYALICE NOWAK: If it --

01:12:36.459 --> 01:12:38.727
practically speaking, if it is

01:12:38.751 --> 01:12:39.975
so similar to a T-shirt that

01:12:39.999 --> 01:12:42.602
you're considered 6109, then

01:12:42.626 --> 01:12:43.975
most likely it's not going to

01:12:43.999 --> 01:12:45.975
have a sweater stitch count.

01:12:45.999 --> 01:12:47.226 position:20%
But again, if a garment is

01:12:47.250 --> 01:12:50.310
excluded from classification as

01:12:50.334 --> 01:12:52.185
6109, it doesn't automatically

01:12:52.209 --> 01:12:56.226
go into 6110 anyway. All we're

01:12:56.250 --> 01:12:57.810
saying is that these features

01:12:57.834 --> 01:13:00.351
excluded it from 6109. It's not

01:13:00.375 --> 01:13:02.810
immediately classified in 6110.

01:13:02.834 --> 01:13:04.185
In practice, they generally do

01:13:04.209 --> 01:13:05.768
end up being classified there,

01:13:05.792 --> 01:13:07.935
but you'd have to consider, you

01:13:07.959 --> 01:13:08.810 position:20%
know, all the other

01:13:08.834 --> 01:13:10.059
considerations for requirements

01:13:10.083 --> 01:13:16.935 position:20%
under 6110.

01:13:16.959 --> 01:13:17.560
>> FUNG KING KONG: Okay. Thank

01:13:17.584 --> 01:13:22.059
you. So even if a slub knit

01:13:22.083 --> 01:13:23.975
fabric is a jersey and is less

01:13:23.999 --> 01:13:25.975
than 200 gram per square inch,

01:13:25.999 --> 01:13:27.643
it would not be considered a

01:13:27.667 --> 01:13:30.975 position:20%
T-shirt?

01:13:30.999 --> 01:13:31.560 position:20%
>> MARYALICE NOWAK: For a

01:13:31.584 --> 01:13:32.643
garment to be classified as a

01:13:32.667 --> 01:13:34.852
T-shirt, it must be either plain

01:13:34.876 --> 01:13:37.935
jersey or plain interlock knit

01:13:37.959 --> 01:13:40.393 position:20%
fabric. And I put up that

01:13:40.417 --> 01:13:44.393 position:20%
headquarters ruling, right?

01:13:44.417 --> 01:13:52.976
That was toward the beginning.

01:13:53.000 --> 01:14:02.602
Not there yet. Yeah. Here.

01:14:02.626 --> 01:14:05.685
It's that headquarters ruling

01:14:05.709 --> 01:14:12.975 position:20%
950855.

01:14:12.999 --> 01:14:13.727
>> FUNG KING KONG: There's two

01:14:13.751 --> 01:14:15.268
people, they would like to see

01:14:15.292 --> 01:14:24.976 position:20%
slide 37, 39 and 40.

01:14:25.000 --> 01:14:32.894
>> MARYALICE NOWAK: 37. Okay.

01:14:32.918 --> 01:14:33.518
>> FUNG KING KONG: 39, and then

01:14:33.542 --> 01:14:34.226 position:20%
40.

01:14:34.250 --> 01:14:42.975
>> MARYALICE NOWAK: Okay. 39.

01:14:42.999 --> 01:14:45.643 position:20%
>> FUNG KING KONG: 40.

01:14:45.667 --> 01:14:49.185 position:20%
>> MARYALICE NOWAK: 40.

01:14:49.209 --> 01:14:49.975 position:20%
>> FUNG KING KONG: Will a

01:14:49.999 --> 01:14:51.852
non-raised graphic tee now go

01:14:51.876 --> 01:14:54.310 position:20%
under 6109 other T-shirt,

01:14:54.334 --> 01:14:57.476 position:20%
regardless of graphic size?

01:14:57.500 --> 01:14:58.059
>> MARYALICE NOWAK: I'm not

01:14:58.083 --> 01:15:00.976
sure what you mean by now. This

01:15:01.000 --> 01:15:21.768
is not a change in practice.

01:15:21.792 --> 01:15:23.101
>> FUNG KING KONG: Is distress

01:15:23.125 --> 01:15:25.101 position:20%
considered conspicuous? In

01:15:25.125 --> 01:15:30.059
other words, more tear, less

01:15:30.083 --> 01:15:32.685 position:20%
tear, tattered?

01:15:32.709 --> 01:15:33.310
>> MARYALICE NOWAK: I'm sorry.

01:15:33.334 --> 01:15:34.268 position:20%
Where are you?

01:15:34.292 --> 01:15:35.059
>> FUNG KING KONG: Wayne, from

01:15:35.083 --> 01:15:39.435 position:20%
Wayne, around 2:46.

01:15:39.459 --> 01:15:40.101
>> MARYALICE NOWAK: Okay. I'm

01:15:40.125 --> 01:16:06.476
getting there. Is distressed --

01:16:06.500 --> 01:16:08.602 position:20%
Wayne, remember what I said

01:16:08.626 --> 01:16:11.560
that's not in those lists that

01:16:11.584 --> 01:16:12.852
we went through today are not

01:16:12.876 --> 01:16:14.476
all inclusive? It sounds like

01:16:14.500 --> 01:16:15.727
you may have a different feature

01:16:15.751 --> 01:16:19.852
for me. Want to send in that

01:16:19.876 --> 01:16:22.975 position:20%
garment for a ruling?

01:16:22.999 --> 01:16:24.643
>> FUNG KING KONG: You might

01:16:24.667 --> 01:16:26.101
have a possible new item on your

01:16:26.125 --> 01:16:28.602 position:20%
list. Are capped sleeves

01:16:28.626 --> 01:16:32.935 position:20%
acceptable under 6109?

01:16:32.959 --> 01:16:39.476
>> MARYALICE NOWAK: Under 6109?

01:16:39.500 --> 01:16:43.185
Where is that? Capping anywhere

01:16:43.209 --> 01:16:45.351 position:20%
but the neckline is an

01:16:45.375 --> 01:16:48.975 position:20%
inconspicuous, non-T-shirt

01:16:48.999 --> 01:16:50.268
feature. So can it go under

01:16:50.292 --> 01:16:52.602
6109? Yes. But it is not a

01:16:52.626 --> 01:16:59.643 position:20%
true T-shirt.

01:16:59.667 --> 01:17:00.268 position:20%
>> FUNG KING KONG: Please

01:17:00.292 --> 01:17:04.975
restate about slub fabric. Do

01:17:04.999 --> 01:17:06.976 position:20%
all T-shirts and similar to

01:17:07.000 --> 01:17:09.518
T-shirts have to be light weight

01:17:09.542 --> 01:17:10.976 position:20%
plain jersey or interlock

01:17:11.000 --> 01:17:12.560 position:20%
fabric, or is that just

01:17:12.584 --> 01:17:13.976 position:20%
underwear T-shirt?

01:17:14.000 --> 01:17:14.852
>> MARYALICE NOWAK: No. All

01:17:14.876 --> 01:17:16.727 position:20%
T-shirts have to be light

01:17:16.751 --> 01:17:18.268 position:20%
weight, plain or interlock

01:17:18.292 --> 01:17:21.226
fabric. It is not classifiable

01:17:21.250 --> 01:17:24.226
as a T-shirt if it is not plain

01:17:24.250 --> 01:17:37.685 position:20%
jersey or plain interlock.

01:17:37.709 --> 01:17:38.226 position:20%
>> FUNG KING KONG: I think

01:17:38.250 --> 01:17:39.975
Andrew got back to your question

01:17:39.999 --> 01:17:41.602
about the third party printing.

01:17:41.626 --> 01:17:44.727 position:20%
He would like to --

01:17:44.751 --> 01:17:45.643
>> MARYALICE NOWAK: Okay. What

01:17:45.667 --> 01:17:48.975 position:20%
time did that come in?

01:17:48.999 --> 01:17:50.518 position:20%
>> FUNG KING KONG: 2:48.

01:17:50.542 --> 01:17:51.768
>> MARYALICE NOWAK: Ob. It's

01:17:51.792 --> 01:17:55.393
weird because my chat is kind of

01:17:55.417 --> 01:17:56.351
truncating on the right side,

01:17:56.375 --> 01:17:57.476
and I don't know why that is.

01:17:57.500 --> 01:17:59.018
So, for example, I can print

01:17:59.042 --> 01:18:00.727
pictures on -- but then I can't

01:18:00.751 --> 01:18:05.143
read it. Fung can you read it?

01:18:05.167 --> 01:18:06.018
>> FUNG KING KONG: Sure. I can

01:18:06.042 --> 01:18:08.059
print pictures on a T-shirt with

01:18:08.083 --> 01:18:10.226
a printer press, but you can go

01:18:10.250 --> 01:18:13.310
elsewhere and get a printed tee

01:18:13.334 --> 01:18:14.975
from a store, which is a third

01:18:14.999 --> 01:18:17.810
party. I'm asking in terms of

01:18:17.834 --> 01:18:18.975
classification, is there any

01:18:18.999 --> 01:18:20.643
difference between printing a

01:18:20.667 --> 01:18:23.975
tee by yourself or having a tee

01:18:23.999 --> 01:18:24.975 position:20%
printed for you by a third

01:18:24.999 --> 01:18:26.727 position:20%
party?

01:18:26.751 --> 01:18:30.602
>> MARYALICE NOWAK: No. No.

01:18:30.626 --> 01:18:32.101
But I mean, is this like for

01:18:32.125 --> 01:18:33.975
export, or is this -- do you

01:18:33.999 --> 01:18:36.975
know what I mean? Like, after

01:18:36.999 --> 01:18:38.310
export, we don't care if you

01:18:38.334 --> 01:18:40.602
print it yourself after it's

01:18:40.626 --> 01:18:41.975
imported, right? Like, are you

01:18:41.999 --> 01:18:43.018
preparing to export to another

01:18:43.042 --> 01:18:47.975 position:20%
country? I -- you know.

01:18:47.999 --> 01:18:48.768
>> FUNG KING KONG: If a tee is

01:18:48.792 --> 01:18:51.476
made from a ribbed fabric like a

01:18:51.500 --> 01:18:53.975 position:20%
traditional underwear style

01:18:53.999 --> 01:18:56.351
tank, but has a regular stitch

01:18:56.375 --> 01:19:02.768
hem, is this a ribbed waistband?

01:19:02.792 --> 01:19:03.685
>> MARYALICE NOWAK: Tee? Say

01:19:03.709 --> 01:19:05.602
it again. Can you -- okay. I

01:19:05.626 --> 01:19:06.976
think I see it. If a tee is

01:19:07.000 --> 01:19:08.976
made from a ribbed fabric like a

01:19:09.000 --> 01:19:10.351 position:20%
-- but then I can't --

01:19:10.375 --> 01:19:10.975 position:20%
>> FUNG KING KONG: Like a

01:19:10.999 --> 01:19:12.602 position:20%
traditional underwear style

01:19:12.626 --> 01:19:17.226
tank, but has a regular stitch

01:19:17.250 --> 01:19:21.602
hem, is this a ribbed waistband?

01:19:21.626 --> 01:19:22.185
>> MARYALICE NOWAK: If it's

01:19:22.209 --> 01:19:23.268
made from ribbed fabric, then

01:19:23.292 --> 01:19:26.018
it's not plain jersey or plain

01:19:26.042 --> 01:19:38.185 position:20%
interlock, right?

01:19:38.209 --> 01:19:38.976
>> FUNG KING KONG: Tracy would

01:19:39.000 --> 01:19:41.685
like to know how she can find

01:19:41.709 --> 01:19:44.018
information to request a ruling.

01:19:44.042 --> 01:19:46.226
Do you have that slide handy?

01:19:46.250 --> 01:19:47.101
>> MARYALICE NOWAK: I do. It's

01:19:47.125 --> 01:19:59.143
at the beginning. Yep. It's

01:19:59.167 --> 01:20:01.018 position:20%
right there.

01:20:01.042 --> 01:20:01.852
>> FUNG KING KONG: Neckline

01:20:01.876 --> 01:20:03.975 position:20%
opening, short sleeves and

01:20:03.999 --> 01:20:07.185 position:20%
jersey is under 6110?

01:20:07.209 --> 01:20:07.975
>> MARYALICE NOWAK: I am not

01:20:07.999 --> 01:20:09.310
going to provide an official

01:20:09.334 --> 01:20:10.185
classification of that garment

01:20:10.209 --> 01:20:11.810
but I will tell you that if it

01:20:11.834 --> 01:20:13.226
has an opening in the neck line,

01:20:13.250 --> 01:20:17.018 position:20%
it's not 6109.

01:20:17.042 --> 01:20:18.268
>> FUNG KING KONG: Thank you.

01:20:18.292 --> 01:20:20.975
Are cap sleeve length -- are cap

01:20:20.999 --> 01:20:23.852 position:20%
sleeve length -- sorry.

01:20:23.876 --> 01:20:24.476
>> MARYALICE NOWAK: Oh, I think

01:20:24.500 --> 01:20:26.226 position:20%
I just saw it. Cap sleeve

01:20:26.250 --> 01:20:29.727 position:20%
length sleeves --

01:20:29.751 --> 01:20:30.310
>> FUNG KING KONG: Excluded

01:20:30.334 --> 01:20:33.975 position:20%
from 6109?

01:20:33.999 --> 01:20:34.768
>> MARYALICE NOWAK: Oh, that's

01:20:34.792 --> 01:20:35.602
interesting, because there's

01:20:35.626 --> 01:20:36.975
capping and then there's cap

01:20:36.999 --> 01:20:38.975
sleeve length. I would have to

01:20:38.999 --> 01:20:41.059
take a look at that garment. We

01:20:41.083 --> 01:20:42.351
may have rulings out there that

01:20:42.375 --> 01:20:43.768
address it but I don't know that

01:20:43.792 --> 01:20:46.976
off the top of my head. And,

01:20:47.000 --> 01:20:48.975
quite honestly, it would most

01:20:48.999 --> 01:20:51.810
likely not be a men's garment,

01:20:51.834 --> 01:20:53.768 position:20%
if what I'm picturing is

01:20:53.792 --> 01:21:00.768 position:20%
correct.

01:21:00.792 --> 01:21:01.351
>> FUNG KING KONG: It seems

01:21:01.375 --> 01:21:02.143
that Andrew is interested in

01:21:02.167 --> 01:21:04.560
this third party products to be

01:21:04.584 --> 01:21:05.975
exported to another country.

01:21:05.999 --> 01:21:06.768
>> MARYALICE NOWAK: Yeah. You

01:21:06.792 --> 01:21:08.435
know what, U.S. Customs doesn't

01:21:08.459 --> 01:21:11.975 position:20%
handle exports. So I would

01:21:11.999 --> 01:21:13.852 position:20%
check with the customs

01:21:13.876 --> 01:21:14.975
department of the country that

01:21:14.999 --> 01:21:21.226
you are looking to import into.

01:21:21.250 --> 01:21:22.059
>> FUNG KING KONG: Thank you.

01:21:22.083 --> 01:21:23.976
Will a non-raised graphic tee

01:21:24.000 --> 01:21:26.727 position:20%
now go under 6109, other

01:21:26.751 --> 01:21:28.975
T-shirt, regardless of graphic

01:21:28.999 --> 01:21:29.602 position:20%
--

01:21:29.626 --> 01:21:31.810
>> MARYALICE NOWAK: I think we

01:21:31.834 --> 01:21:34.143
answered that? But I'm not sure

01:21:34.167 --> 01:21:36.602
what Wendy means by will it now

01:21:36.626 --> 01:21:40.602
go under, because it always did,

01:21:40.626 --> 01:21:43.602
you know, if it's not -- I'm --

01:21:43.626 --> 01:21:44.894
or maybe I'm not understanding

01:21:44.918 --> 01:21:46.185 position:20%
what you mean by the term

01:21:46.209 --> 01:21:50.351 position:20%
graphic. But we're more

01:21:50.375 --> 01:21:51.975
concerned with the method of

01:21:51.999 --> 01:21:53.476
printing than -- I'm not sure

01:21:53.500 --> 01:21:54.768 position:20%
what you mean by graphic

01:21:54.792 --> 01:21:57.101 position:20%
necessarily.

01:21:57.125 --> 01:21:57.975
>> FUNG KING KONG: Thank you.

01:21:57.999 --> 01:22:00.852
What is the lowest duty rate for

01:22:00.876 --> 01:22:03.602 position:20%
a plain cotton T-shirt that

01:22:03.626 --> 01:22:07.518
falls within the specific of

01:22:07.542 --> 01:22:12.393 position:20%
what a T-shirt is?

01:22:12.417 --> 01:22:13.975
>> MARYALICE NOWAK: Depends on

01:22:13.999 --> 01:22:18.643 position:20%
the fiber content.

01:22:18.667 --> 01:22:19.685
>> FUNG KING KONG: Thank you.

01:22:19.709 --> 01:22:20.975
>> MARYALICE NOWAK: I believe

01:22:20.999 --> 01:22:23.975
16 and a half, man-made fiber is

01:22:23.999 --> 01:22:28.602 position:20%
32 percent.

01:22:28.626 --> 01:22:29.226
>> FUNG KING KONG: Thank you.

01:22:29.250 --> 01:22:30.143
And I think that was our last

01:22:30.167 --> 01:22:31.976
question, aside from the thank

01:22:32.000 --> 01:22:32.935 position:20%
yous.

01:22:32.959 --> 01:22:33.975 position:20%
>> MARYALICE NOWAK: Okay.

01:22:33.999 --> 01:22:34.602
>> FUNG KING KONG: One more

01:22:34.626 --> 01:22:35.185 position:20%
just came up.

01:22:35.209 --> 01:22:35.975 position:20%
>> MARYALICE NOWAK: Okay.

01:22:35.999 --> 01:22:36.975 position:20%
>> FUNG KING KONG: Can you

01:22:36.999 --> 01:22:38.935
confirm that a muscle tee falls

01:22:38.959 --> 01:22:44.976 position:20%
out of 6109 to 6110?

01:22:45.000 --> 01:22:45.894
>> MARYALICE NOWAK: I can. I

01:22:45.918 --> 01:22:47.643
think it -- I think I actually

01:22:47.667 --> 01:22:49.018
call it a muscle shirt on that

01:22:49.042 --> 01:23:02.226
slide, didn't I? Yeah. Lack of

01:23:02.250 --> 01:23:08.643 position:20%
sleeves, muscle shirt.

01:23:08.667 --> 01:23:09.268
>> FUNG KING KONG: Thank you.

01:23:09.292 --> 01:23:10.975
I believe you covered all the

01:23:10.999 --> 01:23:12.268 position:20%
questions.

01:23:12.292 --> 01:23:22.727
>> MARYALICE NOWAK: Okay. I

01:23:22.751 --> 01:23:23.852
don't know what questions we've

01:23:23.876 --> 01:23:27.018
missed, but someone named Hemur,

01:23:27.042 --> 01:23:28.768
if my questions aren't being

01:23:28.792 --> 01:23:29.894
answered, absolutely. You have

01:23:29.918 --> 01:23:32.185
my E-mail address. Let's follow

01:23:32.209 --> 01:23:42.852 position:20%
up. Okay?

01:23:42.876 --> 01:23:48.059 position:20%
Okay. Thank you, everyone!

01:23:48.083 --> 01:23:48.975 position:20%
>> Thank you for attending

01:23:48.999 --> 01:23:53.727 position:20%
today's webinar. This is a

01:23:53.751 --> 01:23:56.393
reminder that the webinar will

01:23:56.417 --> 01:23:58.975
be posted on the CBP Web site.

01:23:58.999 --> 01:24:00.975
Thank you for joining us today,

01:24:00.999 --> 01:24:05.975
and enjoy the rest of your day.

01:24:05.999 --> 01:24:05.999 position:20%
[Webinar concluded].