WEBVTT

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>> Good afternoon, everyone. My
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name is Lynn banks with the Office of
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Trade relations. Today's Webinar is
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heading 6212 body-supporting garments
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and beyond. And it's part of the
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education commodity specific 2023
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webinar series. And has an anticipated
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duration of 90 minutes. We have a few
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housekeeping items. We ask that
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everyone be kept on mute during the
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presentation so we can make clear of any
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background noise. If you have any
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questions or comments, we invite you to
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type them into the chat box at any time
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during the presentation. We will answer
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as many questions as we can at the end
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of the presentation. And the Continuing
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Education credit code will be placed in
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the chat box during the presentation.
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Today's presenter is National Import
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Specialist, Karen Sikorski. Ms. Karen
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Sikorski, over to you.
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>> KAREN SIKORSKI: Good afternoon,
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everyone. I decided to come on camera
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and say hello to everybody, because it's
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so much easier to relate to people when
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you can see them. Unfortunately, I
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won't be able to be on camera for the
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entire seminar, and that's only because
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I have couple of different set ups here,
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and I can't look directly at the camera.
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So I thank you for joining us. And
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we'll get started.
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Okay, I have couple of slides here
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that I'm going to let you read at your
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leisure. First up with is our mission
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for customs and our Office of Trade.
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The next one is our disclaimer which
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basically is telling you this webinar is
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for general information purposes only.
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It's educational. We're providing
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guidance. The information here that's
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related can't be considered to be -- you
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can't rely on it and consider it
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reasonable care. There's more research
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that needs to be done and just be aware
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this is for educational purposes and
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don't hold me feet to the fire. Also
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another disclaimer regarding our images.
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Everything that we've got here is
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either public domain, or we have
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obtained the appropriate Copyright
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licenses. And again, everything is here
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just for educational purposes.
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We always have to mention binding
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rulings. Here's the links for that
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where you can request binding rules for
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the National Import Specialist. We can
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cover classification origin, free trade
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agreement and marketing. And the
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easiest way is to go to c bp.gov and
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input the words electric Nick ruling.
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We ask that you send samples for apparel
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and pictures are always helpful as well.
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Our basic outline today is pretty
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simple, although, we'll get into some
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complicated stuff. We're just going to
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touch on some of the bakes of
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classification for heading 6212, cover
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some terms in definition., especially
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the word port. We're going to talk
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about the body support being the
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paramount function or primarily purpose
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for the garment as established by
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headquarters ruling and a court case and
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we're going to focus the webinar
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primarily on brassieres, sports bras,
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bralettes, support tanks and support cam
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sole style garments and case studies for
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ambiguous garments. Heading 2612 itself
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covers brassieres, girdles, corsets,
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suspenders, garters and similar articles
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and parts thrf, whether or not knitted
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or crocheted. We have a traditional
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bra. A corset, which is going to
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compress the waist. A corset, which is
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British term for suspender and garter
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belt to hold up stockings. We talk
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about the terms of the heading of the
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HTS. We basically mean the words of the
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HTS.
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And when we say HTS, it's just an
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abbreviation for the Harmonized Tariff
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Schedule of the United States, which we
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also simply refer to as the tariff.
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This slide and the next are the
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explanatory notes for heading 2612 in
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their entirety. InterAlia is a word and
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it means among other things. So intran
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tore notes are going to cover the terms
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of the heading which we previously just
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saw. And then these explanatory notes
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add some words like panty girdle,
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corset, et cetera. So you always want
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to look at both, terms of the heading
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and explanatory notes.
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When people talk about my commodity
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line, they refer to some of the items
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that I handle as body-supporting
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garments and I thought to myself, where
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does that come from? It's not in the
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tariff. Well, the terminology
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"body-supporting" actually comes from
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the explanatory notes, which say the
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heading covers articles of a kind
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designed for wear as body-supporting
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garments or supports for certain other
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articles of apparel. The word "support"
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actually means like very briefly to bear
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the weight of. The article in this
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heading may be made of any textile
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material including knitted or crocheted
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fabrics. And Chapter 62 note 1 also
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drives that point home, even though
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Chapter 62 is limited to articles of
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apparel and clothing, accessories not
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knitted. And this is how bras fit into
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heading 6212.
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So let's get right into it. Here's
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some additional guidance from a few
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headquarters ruling regarding
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body-supporting garments. The article
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should be supported throughout HQ963631.
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The examine particulars to heading 6212
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are United by the fact that they support
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apparel or other items like garters or
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forms of garments like a bra, and
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generally worn underneath other
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garments. An example would be a
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maternity belt we see here. That's
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according to headquarters ruling can
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HQ963631. And I put in here postectomy
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compression, and this would go into
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heading 6212 as well. This is something
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recommended by a surgeon after a
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mastectomy, which is breast cancer
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surgery to remove one or both breasts.
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Vest such as this would offer
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compression, tight fit or good amount of
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spandex, very wide elasticized bands
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among other features.
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And this garment would be designed
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to enhance healing for disturbed tissue
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layers after surgery and could aid in
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easing swelling, pain and discomfort.
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There are some more elucidating
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definition for the word support. To
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bare up or hold up. A load mass,
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structure, part, service as a foundation
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for. To sustain or withstand weight,
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pressure, or strain, without giving way,
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to serve as a prop for. HQ963631 tell
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us in finding the support, it's a means
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to bare the weight of especially from
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below to hold in position, to prevent
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from falling, sinking, or slipping. H
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this must be the primary function as
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established by HQ950741.
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The word are principle actually
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means principle, basic, fundamental. So
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for the past 30 years or more, CBP has
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been dealing with body support as a
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primarily support of any garment that's
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classified in heading 6212. In this
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case here, the Victoria's Secret Direct
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case, the Court told us that the items
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classified in heading 6212 have as
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either their essential characteristic
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and purpose either of support of a part
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of the body or support of a garment.
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And this is actually a picture of the
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court of international trade building
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in New York, New York.
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So before we move on to some more of
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this information, let's take just a few
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minutes and maybe you could tell me in
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the chat box how you happen to be
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connected to apparel imports. You know,
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why are you here? Who do you work for?
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Are you an import specials with U.S.
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customs? Or are you from the trade and
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you're working, you know, with bras or
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it things like that. If you're there, I
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think I can see the chat box. Yes,
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we've got some import special lists.
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Some entry specialists. Some brokers.
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Tariff engineers. Broker. Anybody want
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to mention what company they're from?
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Quality control. Trade compliance.
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Talbot. Somebody taking the brokerage
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exam. Customer compliance and other
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broker. Logistics. Macy's. Wonderful.
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Thank you. I'm so glad we have such a
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variety of people here.
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It's really good to know that we're
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reaching everybody. Somebody is an Uber
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driver. Awesome. Okay. Thanks, I
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guess we have to move on and go back to
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work. But it's great to know you a
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little bit. And I'll keep watching
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outreach the corner of my eye. So in
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this slide here, what we've got is an
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example from the Victoria's Secret case.
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This is just a picture I came up. It's
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not actually part of the case. But
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during that Victoria's Secret case,
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garments were ruled to be of a dual
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purpose, both coverage and support. The
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degree of coverage was determined to be
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more than that provided by a brassiere.
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The Court found that support is the
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paramount function of 6212. And that
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the premise of the function is not
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overwritten by additional outerwear
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coverage function so significant as to
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dominate or roughly be the same
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importance of the support function.
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This is kind of a key aspect to the
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case.
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A shelf cam sole is a cam sole with
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a shelf bra. This is an extra piece of
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fabric with elastic under wand built
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into the garment that provides light
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support to the breast. And I showed you
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a picture here.
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So some of the definitions we're
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going to talk about today in detail I
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have to do about brassieres and then
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we're going to talk a little bit about
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tank styles, camisoles, and abbreviated
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upper body garments and tops. And best
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place to go for customs definition for
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these terms is the apparel terminology
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informed compliance publication. And
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that's what we'll cover the bras in more
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detail in a moment. But we're going to
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talk about the other ones here in a
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little bit, just so you know these
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definitions are here. So report to
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compliance publications, I've included
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the definitions for other types of
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garments from the ICP, because they
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become helpful when we start to talk
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about garments that cross the line
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between bras and upper body garments
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worn as outerwear. These definitions
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can help us understand the differences
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between items that serve as bras and
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those that are simply tops.
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So here they talk about in the ICP
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about tank styles and similar upper body
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garments. And they end up being in 6211
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here according to the ICP due to lack of
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coverage. And we can translate this to
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heading 6114 as well where we put these
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garments if they were knit. So this
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group encompasses 3 types of garments.
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Sleeve-less tank styles, cam stoles, and
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abbreviated upper body garments.
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Sleeve-less tank styles are providing
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limit the shoulder coverage and how this
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can have a U neck, V neck, or scooped
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neck, et cetera. Camisoles are garments
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that provide limited shoulder coverage.
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They normally have spaghetti style type
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or ribbon type straps, and they're cut
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straight across from the top edge, from
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the side seam to side seam, either in
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the front or back or both. And then we
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have upper abbreviated upper body
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garments which lack coverage either at
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the shoulder, arm hole, or waist, and
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this would include things like bandeaus,
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Bouse yeahs, and hall through and tube
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tops and I just discovered this in the
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informed compliance publication and
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found it had real application to my line
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when I'm trying to decide if something
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is going to be a support garment or bra
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in 6212 or it's not going to in line,
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and it has to go to heading 6114, or
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heading 6211.
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This is another one of those
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definitions from the ICP where they talk
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about tops and heading 6114, and they
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say which is the knit provision and they
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say tops generally have limited coverage
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of the neck and shoulder area, and/or do
00:15:35.314 --> 00:15:40.233
not reach the waist. And these terms
00:15:40.233 --> 00:15:42.502
are sometimes used to describe garments
00:15:42.502 --> 00:15:46.786
such as halter tops, tube tops, or cam
00:15:46.786 --> 00:15:49.277
SOLs, and I provided an example of each
00:15:49.277 --> 00:15:52.951
one here. Halter top, tube tops, and
00:15:52.951 --> 00:15:56.351
camisole. And word about camisoles,
00:15:56.351 --> 00:15:58.694
knit camisole garment can be ambiguous
00:15:58.694 --> 00:16:01.269
because they can be worn for a number of
00:16:01.269 --> 00:16:03.144
different reasons. They can be
00:16:03.144 --> 00:16:06.054
classified in heading 6114, but they
00:16:06.054 --> 00:16:10.931
also can be mine if they're under an
00:16:10.931 --> 00:16:13.252
undershirt or turn out to be a support
00:16:13.252 --> 00:16:18.546
style camisole and heading 6212.
00:16:18.546 --> 00:16:22.532
So for brassieres, in 6212, these
00:16:22.532 --> 00:16:25.659
are garments that are worn to mold and
00:16:25.659 --> 00:16:27.881
or support the breast. They typically
00:16:27.881 --> 00:16:29.871
consists of two cups held in place with
00:16:29.871 --> 00:16:32.478
shoulder straps and elastic in center
00:16:32.478 --> 00:16:34.810
back. Long-line brassieres extend
00:16:34.810 --> 00:16:37.840
toward the waist and typically have
00:16:37.840 --> 00:16:40.854
vertical stays or boning. Sports bras
00:16:40.854 --> 00:16:43.404
usually feature wider shoulder straps,
00:16:43.404 --> 00:16:50.481
two-ply frawnt panel, mesh fabric, and
00:16:50.481 --> 00:16:53.782
elasticized bottom bands.
00:16:53.782 --> 00:17:04.080
In headquarters ruling 9HQ591264,
00:17:04.080 --> 00:17:07.226
T-back sports bras were ruled as customs
00:17:07.226 --> 00:17:10.212
to qualify as cups, hook and eye
00:17:10.212 --> 00:17:11.870
closure, under wire stays, and it was
00:17:11.870 --> 00:17:13.779
determined that so long as the articles
00:17:13.779 --> 00:17:15.919
were treated as foundation wear in the
00:17:15.919 --> 00:17:18.156
industry, and possessed the support
00:17:18.156 --> 00:17:20.760
features, they weren't precluded from
00:17:20.760 --> 00:17:24.303
classification in heading 6212. Sports
00:17:24.303 --> 00:17:29.844
bras are treated as foundation rather
00:17:29.844 --> 00:17:32.084
than outerwear. They're designed to
00:17:32.084 --> 00:17:35.484
movement and exercise and can be quite
00:17:35.484 --> 00:17:37.827
sturdy de. It will sometimes be
00:17:37.827 --> 00:17:40.410
differentiated as offering support for
00:17:40.410 --> 00:17:42.606
activities that are low impact, such as
00:17:42.606 --> 00:17:44.412
this one, which could be used for
00:17:44.412 --> 00:17:47.588
something like yoga. Or medium impact,
00:17:47.588 --> 00:17:50.582
say you would use it to go hiking. Or
00:17:50.582 --> 00:17:52.816
high impact, which would be something
00:17:52.816 --> 00:17:55.146
like a bra which you would use for
00:17:55.146 --> 00:17:59.230
returning. This particular one has
00:17:59.230 --> 00:18:01.837
extra details in here, some extra mesh,
00:18:01.837 --> 00:18:04.344
some molded cups, some pretty firm
00:18:04.344 --> 00:18:08.488
straps. Some very adjustable bra and
00:18:08.488 --> 00:18:15.450
hook eye closure in the back. What is
00:18:15.450 --> 00:18:17.863
the foundation wear? Well, foundation
00:18:17.863 --> 00:18:20.877
wear is any garment that support or
00:18:20.877 --> 00:18:23.583
controls the woman's figure. Sometimes
00:18:23.583 --> 00:18:25.330
it's associated with CORE let's or
00:18:25.330 --> 00:18:27.938
corsets. But this also covers garments
00:18:27.938 --> 00:18:32.071
such as girdles, panty girdles and
00:18:32.071 --> 00:18:33.923
brassieres. Christian Dior said without
00:18:33.923 --> 00:18:36.628
foundation, there can be no fashion.
00:18:36.628 --> 00:18:38.604
Properly fitted fashion garments are
00:18:38.604 --> 00:18:40.616
the building blocks that make clothes
00:18:40.616 --> 00:18:43.308
look their best, especially for women.
00:18:43.308 --> 00:18:45.655
Here we have the bullet bra, but what's
00:18:45.655 --> 00:18:48.528
the point?
00:18:48.528 --> 00:18:51.778
A bra does not have to be worn as a
00:18:51.778 --> 00:18:55.012
under garment only, it need only possess
00:18:55.012 --> 00:18:57.089
certain requisite body-supporting
00:18:57.089 --> 00:19:00.753
functions. According to headquarters
00:19:00.753 --> 00:19:04.731
ruling 950685, some typical features
00:19:04.731 --> 00:19:07.215
include underwear, adjustable shoulder
00:19:07.215 --> 00:19:09.759
straps, stays, adjustable hook and eye
00:19:09.759 --> 00:19:12.339
closures, traditional bra sizing,
00:19:12.339 --> 00:19:15.317
support fabric. I wanted to say little
00:19:15.317 --> 00:19:18.447
bit about the word "stays." Because
00:19:18.447 --> 00:19:20.929
that can be another term for the word
00:19:20.929 --> 00:19:23.456
boning. Boning is a sewing technique
00:19:23.456 --> 00:19:29.127
that actually fixes bones into a seam.
00:19:29.127 --> 00:19:32.364
Today, it's made of plastic or metal in
00:19:32.364 --> 00:19:34.488
and provide support and they can give
00:19:34.488 --> 00:19:37.054
the garment special sort of structure.
00:19:37.054 --> 00:19:39.406
They can stabilize and hold the fabric
00:19:39.406 --> 00:19:42.177
together and actually create seller
00:19:42.177 --> 00:19:44.516
structure. Designers use bra bones to
00:19:44.516 --> 00:19:48.967
help maintain the shape of a bra.
00:19:48.967 --> 00:19:52.804
Headquarters ruling 951264 tells us the
00:19:52.804 --> 00:19:55.061
customs does not support the
00:19:55.061 --> 00:19:57.088
body-supporting garments. Must have
00:19:57.088 --> 00:20:00.706
cups, heat-molded or otherwise
00:20:00.706 --> 00:20:02.867
classified as brassiere, long as
00:20:02.867 --> 00:20:04.926
articles are treated as foundation wear
00:20:04.926 --> 00:20:07.215
in the industry and requisite support
00:20:07.215 --> 00:20:10.013
features are present. Traditional bras
00:20:10.013 --> 00:20:13.799
seem to all have cup, but something like
00:20:13.799 --> 00:20:16.233
this which is a low impact sports bra
00:20:16.233 --> 00:20:20.961
that does not.
00:20:20.961 --> 00:20:23.069
For brassieres, first thing we need
00:20:23.069 --> 00:20:24.988
to determine is whether the bra has
00:20:24.988 --> 00:20:28.361
lace, net, or embroidery. Most bras we
00:20:28.361 --> 00:20:31.250
see do not actually contain lace, net,
00:20:31.250 --> 00:20:33.947
or embroidery for tariff purposes.
00:20:33.947 --> 00:20:35.856
Whether there's a duty difference or
00:20:35.856 --> 00:20:37.759
not, it's always in your best interest
00:20:37.759 --> 00:20:41.743
to classify accurately as possible.
00:20:41.743 --> 00:20:45.389
Actually, our division director, Steve
00:20:45.389 --> 00:20:47.511
Mac said the other day that it's always
00:20:47.511 --> 00:20:50.128
better to do things right the first time
00:20:50.128 --> 00:20:54.405
and, I wholeheartedly agree, because do
00:20:54.405 --> 00:20:57.897
what you feel in your heart to be right.
00:20:57.897 --> 00:21:00.164
For you will be criticized anyway
00:21:00.164 --> 00:21:04.018
according to Eleanor Roosevelt. The
00:21:04.018 --> 00:21:07.548
bras that contain lace, net, embroidery,
00:21:07.548 --> 00:21:10.356
I provided subheading of there, the
00:21:10.356 --> 00:21:12.998
specific cup subheading. You would want
00:21:12.998 --> 00:21:15.275
to determine what containing means and
00:21:15.275 --> 00:21:17.612
containing actually means a significant
00:21:17.612 --> 00:21:21.342
amount for the tariff. The lace, net,
00:21:21.342 --> 00:21:23.628
or embroidery for the bras in this
00:21:23.628 --> 00:21:25.334
section should be featured on the main
00:21:25.334 --> 00:21:28.611
body of the garment, not solely used as
00:21:28.611 --> 00:21:31.417
trim or edging. And I had some
00:21:31.417 --> 00:21:32.932
assistance coming up with some of these
00:21:32.932 --> 00:21:36.973
definitions for lace, net, or embroid
00:21:36.973 --> 00:21:41.072
refrom my team. And I can tell you that
00:21:41.072 --> 00:21:47.511
lace, true lace is ornamental or open
00:21:47.511 --> 00:21:49.712
fabric formed by intertwisting of
00:21:49.712 --> 00:21:52.850
thread. True lace is neither woven or
00:21:52.850 --> 00:21:55.837
knitted. For net, this is open fabric
00:21:55.837 --> 00:21:58.368
formed by weaving, knotting, or twisting
00:21:58.368 --> 00:22:01.507
of yarn or thread to form a meshwork.
00:22:01.507 --> 00:22:05.755
Net is not knit. Embroidery is obtained
00:22:05.755 --> 00:22:08.815
by working with embroidery threads on
00:22:08.815 --> 00:22:10.648
pre-existing ground of fabric in order
00:22:10.648 --> 00:22:12.965
to produce an ornamental effect on that
00:22:12.965 --> 00:22:13.953
ground.
00:22:13.953 --> 00:22:17.487
So for these bras that are in the
00:22:17.487 --> 00:22:22.807
section where they're candidating net,
00:22:22.807 --> 00:22:24.905
lace, or embroidery, many places have
00:22:24.905 --> 00:22:27.820
that but they're usually lace-like or
00:22:27.820 --> 00:22:30.743
net-like knit fabrics where you can see
00:22:30.743 --> 00:22:34.627
the interlinking loops, therefore, most
00:22:34.627 --> 00:22:37.327
bras are going to fall into the "other"
00:22:37.327 --> 00:22:41.790
category which is 6212.10.90. You can
00:22:41.790 --> 00:22:44.112
see the explanatory notes for more
00:22:44.112 --> 00:22:46.616
specific information on lace, net, or
00:22:46.616 --> 00:22:51.906
embroidery.
00:22:51.906 --> 00:22:54.762
Like I said before, true lace is an
00:22:54.762 --> 00:22:58.668
open work fap brick. It can be made by
00:22:58.668 --> 00:23:02.003
hand with bobbins and pins, Needles,
00:23:02.003 --> 00:23:04.246
hooks, or by machinery. The machinery
00:23:04.246 --> 00:23:06.477
for making lace came into being in the
00:23:06.477 --> 00:23:11.453
very early 1800s in Nottingham England.
00:23:11.453 --> 00:23:13.876
Yes, Robin Hood territory. Machines
00:23:13.876 --> 00:23:17.212
were made to make garments of handmade
00:23:17.212 --> 00:23:21.780
lace. 1813, John levers improved the
00:23:21.780 --> 00:23:27.220
machine and levers lace became the
00:23:27.220 --> 00:23:29.182
well-known use. And cuss testimonies
00:23:29.182 --> 00:23:33.650
recognize as true lace. Leavers. So
00:23:33.650 --> 00:23:35.798
you might look at both sets of bra and
00:23:35.798 --> 00:23:38.601
say they're lace. Well, here on the
00:23:38.601 --> 00:23:42.009
left retails for $550 and actually made
00:23:42.009 --> 00:23:45.219
with Leavers Lace. And is this is one
00:23:45.219 --> 00:23:47.153
of the bras that's going to be showing
00:23:47.153 --> 00:23:50.451
as being made with lace. But on the
00:23:50.451 --> 00:23:54.877
right-hand side here, we have some bra
00:23:54.877 --> 00:23:59.093
let's that have lace-like fascia for $19
00:23:59.093 --> 00:24:04.267
for 5 of them and $3.80 per unit. So
00:24:04.267 --> 00:24:06.242
that's a good example of what is
00:24:06.242 --> 00:24:09.472
lace-like fabric and not a true lace.
00:24:09.472 --> 00:24:16.412
These are some bras with nets. This
00:24:16.412 --> 00:24:20.366
is a meshwork originally made by hand,
00:24:20.366 --> 00:24:24.849
net is also made by machine with varying
00:24:24.849 --> 00:24:27.842
size and fineness. That's occurring in
00:24:27.842 --> 00:24:31.726
many forms to fine dress nets to fish
00:24:31.726 --> 00:24:34.415
nets of great variety. You see the net
00:24:34.415 --> 00:24:37.160
here is featured on the main body of the
00:24:37.160 --> 00:24:40.093
bra. Just what we need to be classified
00:24:40.093 --> 00:24:43.604
as a net section we talked about smght.
00:24:43.604 --> 00:24:45.558
Embroidery is obtained working with
00:24:45.558 --> 00:24:48.151
threads on a pre-existing ground in
00:24:48.151 --> 00:24:52.249
order to produce an ornamental effect on
00:24:52.249 --> 00:24:54.673
that net ground. This definition is
00:24:54.673 --> 00:24:57.278
from the explanatory notes. Here, what
00:24:57.278 --> 00:24:59.041
we have is something that was stated to
00:24:59.041 --> 00:25:04.822
be a tool fabric under wire cup bra
00:25:04.822 --> 00:25:10.181
embroideried with colorful fine Apple's.
00:25:10.181 --> 00:25:12.536
Embroidery must be significant in this
00:25:12.536 --> 00:25:14.417
section which can be important or
00:25:14.417 --> 00:25:16.442
noteworthy. So I would consider this
00:25:16.442 --> 00:25:19.646
bra with embroidery, because the
00:25:19.646 --> 00:25:21.522
pineapples are so significant. So we're
00:25:21.522 --> 00:25:24.100
about halfway through this big long
00:25:24.100 --> 00:25:26.679
presentation. And if you would like to
00:25:26.679 --> 00:25:29.014
take just a moment to get up and do a
00:25:29.014 --> 00:25:32.309
halfway stretch, you have permission to
00:25:32.309 --> 00:25:34.368
do so. I'm going to stand up and move
00:25:34.368 --> 00:25:37.019
around a little bit. Maybe get a sip of
00:25:37.019 --> 00:25:39.397
water. I think it's hard to concentrate
00:25:39.397 --> 00:25:41.939
on something like this for a full hour.
00:25:41.939 --> 00:25:44.057
So if you want to step away for a
00:25:44.057 --> 00:25:47.935
minute, please feel free. It's
00:25:47.935 --> 00:25:50.906
important to do that, to take your eyes
00:25:50.906 --> 00:25:53.859
away from the screen, and maybe your
00:25:53.859 --> 00:26:02.739
ears away from my voice for a moment.
00:26:02.739 --> 00:26:04.611
You can let me know if you want to, if
00:26:04.611 --> 00:26:06.733
you don't, you can just continue to
00:26:06.733 --> 00:26:09.216
stretch. You can let me know if you're
00:26:09.216 --> 00:26:11.869
willing to take just a few minutes out
00:26:11.869 --> 00:26:16.117
of this presentation where we constantly
00:26:16.117 --> 00:26:18.237
hammer away at classification to explore
00:26:18.237 --> 00:26:21.555
little bit of history.
00:26:21.555 --> 00:26:24.839
I started to do some research some
00:26:24.839 --> 00:26:27.207
of this topic, and I probably got little
00:26:27.207 --> 00:26:30.752
more into it than I needed to. But I
00:26:30.752 --> 00:26:33.583
think it's sometimes helpful because it
00:26:33.583 --> 00:26:35.530
makes you understand where some of these
00:26:35.530 --> 00:26:38.069
things come from, like we talk about
00:26:38.069 --> 00:26:40.749
bones in a bra. They actually used
00:26:40.749 --> 00:26:45.027
bones. It's fascinating. So please,
00:26:45.027 --> 00:26:47.153
everyone is begging for more history
00:26:47.153 --> 00:26:48.924
because they just don't want to look at
00:26:48.924 --> 00:26:51.178
the tariff, the book that makes you go
00:26:51.178 --> 00:26:54.132
blind. That's what it's exactly
00:26:54.132 --> 00:26:57.137
designed. I didn't need glasses most of
00:26:57.137 --> 00:26:58.946
my adult life until I started working
00:26:58.946 --> 00:27:00.695
for customs, and then sure enough,
00:27:00.695 --> 00:27:02.408
steering at those little figures all the
00:27:02.408 --> 00:27:06.651
time, I had to get glasses. So, thank
00:27:06.651 --> 00:27:09.318
you for your patience, and thank you for
00:27:09.318 --> 00:27:11.516
your willingness to entertain me with
00:27:11.516 --> 00:27:17.715
the history. So we can move on. Bras
00:27:17.715 --> 00:27:19.731
actually include a great diversity of
00:27:19.731 --> 00:27:21.609
styles and methods of construction. So
00:27:21.609 --> 00:27:23.796
to understand their purpose, we're going
00:27:23.796 --> 00:27:26.092
to do just a little primer on the
00:27:26.092 --> 00:27:29.347
history of the bra. There is evidence
00:27:29.347 --> 00:27:31.812
women have worn various garments since
00:27:31.812 --> 00:27:34.680
ancient times to cover or support the
00:27:34.680 --> 00:27:36.912
breast. This actually is a mosaic
00:27:36.912 --> 00:27:43.795
created in Sisley in the 4th century AD,
00:27:43.795 --> 00:27:48.073
colloquially known as the bikini girls.
00:27:48.073 --> 00:27:50.671
You can see our girl on the left here
00:27:50.671 --> 00:27:53.417
using the little dumb bell similar to
00:27:53.417 --> 00:27:55.589
what we use today. So the more things
00:27:55.589 --> 00:28:04.558
change, the more they stay the same.
00:28:04.558 --> 00:28:07.042
The FEMA bust was encased in the corsets
00:28:07.042 --> 00:28:11.188
from the western world to 16th and early
00:28:11.188 --> 00:28:14.315
20th Century. What formed as a bodice
00:28:14.315 --> 00:28:18.119
that pushed the body upward made of
00:28:18.119 --> 00:28:20.847
under garment made of whale bone and
00:28:20.847 --> 00:28:24.219
steel that encircled the ribs and
00:28:24.219 --> 00:28:27.365
compressed the natural waist. Corsets
00:28:27.365 --> 00:28:31.097
evolved over the use and helped shaped
00:28:31.097 --> 00:28:33.475
the body into distinctive silhouettes as
00:28:33.475 --> 00:28:35.944
dictated by the fashions of the time.
00:28:35.944 --> 00:28:38.234
Women everywhere were relieved when
00:28:38.234 --> 00:28:41.844
corsets were fashion from the early
00:28:41.844 --> 00:28:44.228
1900s. When corsets became
00:28:44.228 --> 00:28:45.657
unfashionable, brassieres and padding
00:28:45.657 --> 00:28:47.907
helped to project display and emphasize
00:28:47.907 --> 00:28:52.401
the bust. In 1893, New Yorker Marie to
00:28:52.401 --> 00:28:56.642
you sick was granted a patent for breast
00:28:56.642 --> 00:28:58.166
supporter as they described as
00:28:58.166 --> 00:29:03.220
modification of the corset. Which was
00:29:03.220 --> 00:29:05.635
similar to a modern-day push-up bra and
00:29:05.635 --> 00:29:08.378
plate made of metal or other stuff
00:29:08.378 --> 00:29:11.122
material fit against the torso of the
00:29:11.122 --> 00:29:13.744
breast. It was covered with fabric and
00:29:13.744 --> 00:29:15.922
had a pocket for each breast. Women
00:29:15.922 --> 00:29:18.417
everywhere marched on with the
00:29:18.417 --> 00:29:21.386
discomfort until the first modern bra
00:29:21.386 --> 00:29:27.495
was invented by Mary Phelps Jacob, who
00:29:27.495 --> 00:29:30.540
did not like bones sticking out from
00:29:30.540 --> 00:29:34.033
dawning a sheer evening gown for a
00:29:34.033 --> 00:29:36.453
debutante ball. She used this
00:29:36.453 --> 00:29:39.729
alternative using two handkerchief plus
00:29:39.729 --> 00:29:41.804
some ribbon. She patented the garment
00:29:41.804 --> 00:29:45.959
in 1914, thereby freeing women from the
00:29:45.959 --> 00:29:48.032
tyranny of corsets forever according to
00:29:48.032 --> 00:29:50.853
Vanity Fair magazine. Mary sold the
00:29:50.853 --> 00:29:53.397
bras to friends for $1. And then found
00:29:53.397 --> 00:29:55.931
a factory in Boston staffed by two
00:29:55.931 --> 00:29:57.793
women. After making a few hundred bras
00:29:57.793 --> 00:29:59.528
and receiving some orders from the
00:29:59.528 --> 00:30:03.143
Department stores, she was persuaded by
00:30:03.143 --> 00:30:05.500
her husband to clothes the company. She
00:30:05.500 --> 00:30:09.204
sold the patent to Warner Bros. corset
00:30:09.204 --> 00:30:11.841
company for $1,500. In the next 30
00:30:11.841 --> 00:30:14.704
years, Warner Bros. made more than $15
00:30:14.704 --> 00:30:17.314
million from the design as they began
00:30:17.314 --> 00:30:22.702
producing the garment.
00:30:22.702 --> 00:30:25.300
While we could feel rather sorry for
00:30:25.300 --> 00:30:27.412
Mary who lost out on the fortune to be
00:30:27.412 --> 00:30:30.633
made on her bras, she actually led a
00:30:30.633 --> 00:30:32.954
fascinating life despite this. She
00:30:32.954 --> 00:30:36.867
divorced her upper-class husband in 1932
00:30:36.867 --> 00:30:41.865
for the more Roguer hear Crossley.
00:30:41.865 --> 00:30:43.996
Harry confessed his love for her and
00:30:43.996 --> 00:30:47.765
they took off to join ex-pats in Europe
00:30:47.765 --> 00:30:52.747
where she changed her name to Coress
00:30:52.747 --> 00:30:55.213
Crosby. And she's living life here with
00:30:55.213 --> 00:31:00.594
her canopy and her umbrella.
00:31:00.594 --> 00:31:04.815
It was there in Europe that Caresse
00:31:04.815 --> 00:31:08.180
who embodied woman who has it all who
00:31:08.180 --> 00:31:12.334
had her picture painted than none other
00:31:12.334 --> 00:31:14.142
than Salvador Dali. She became a
00:31:14.142 --> 00:31:19.686
well-known New Yorker. And made
00:31:19.686 --> 00:31:21.907
lifelong friends with Dali. She and
00:31:21.907 --> 00:31:23.695
Harry founded a publishing company that
00:31:23.695 --> 00:31:26.029
was actually responsible for publishing
00:31:26.029 --> 00:31:28.338
the early works of authors who would
00:31:28.338 --> 00:31:32.332
later become such famous luminaries as
00:31:32.332 --> 00:31:38.678
earnest Hemingway, aniece and Charles
00:31:38.678 --> 00:31:45.485
Pokowsky and she supported antiwar
00:31:45.485 --> 00:31:47.417
organization. Fascinating story. Back
00:31:47.417 --> 00:31:48.623
to bras.
00:31:48.623 --> 00:31:51.001
So there are various different types
00:31:51.001 --> 00:31:55.356
of bras. And I'll mention a few. The
00:31:55.356 --> 00:31:57.997
T-shirt, padded, balance come net, back
00:31:57.997 --> 00:32:00.868
less, strapless, push up, wireless,
00:32:00.868 --> 00:32:04.096
plunge, racer back, under wire,
00:32:04.096 --> 00:32:08.852
convertible, cupless, full coverage,
00:32:08.852 --> 00:32:13.170
front, closure, bandeau,, et cetera.
00:32:13.170 --> 00:32:15.591
And these are some pictures to give you
00:32:15.591 --> 00:32:17.430
an idea what the different types of bras
00:32:17.430 --> 00:32:20.790
are. If you can see, virtually all of
00:32:20.790 --> 00:32:22.789
them here have straps except for the
00:32:22.789 --> 00:32:25.778
bandeau. This particular plunge one
00:32:25.778 --> 00:32:28.155
doesn't, but sometimes they do. And the
00:32:28.155 --> 00:32:32.820
strapless one clearly is without straps.
00:32:32.820 --> 00:32:34.785
The T-shirt bra is actually a very
00:32:34.785 --> 00:32:37.816
common popular bra, because the molded
00:32:37.816 --> 00:32:41.149
cups provide modest tea and can be
00:32:41.149 --> 00:32:43.840
practically invisible when wearing
00:32:43.840 --> 00:32:46.562
lightweight t-shirts. They can include
00:32:46.562 --> 00:32:50.984
underwear like this one or be wire-free.
00:32:50.984 --> 00:32:53.810
Maternity bras are souped-up versions
00:32:53.810 --> 00:32:56.921
of regular bras. They're designed to
00:32:56.921 --> 00:32:59.066
support the body during pregnancy. They
00:32:59.066 --> 00:33:01.938
may include wider straps, softer fabric,
00:33:01.938 --> 00:33:04.620
extra hooks, or other features that can
00:33:04.620 --> 00:33:07.715
accommodate an expanding bust or rib
00:33:07.715 --> 00:33:14.055
cage. A mastectomy bras has special
00:33:14.055 --> 00:33:19.799
features to hold silicone bust forms.
00:33:19.799 --> 00:33:21.994
Nursing bras have features such as a
00:33:21.994 --> 00:33:25.889
clasp where the cup meets the strap that
00:33:25.889 --> 00:33:28.455
make it easier to nurse a baby, or to
00:33:28.455 --> 00:33:32.449
get access to breast milk for pumping.
00:33:32.449 --> 00:33:36.053
These are some -- well, the bralette,
00:33:36.053 --> 00:33:37.860
I'm going to give you some definitions
00:33:37.860 --> 00:33:42.494
here. It is known as a soft bra with no
00:33:42.494 --> 00:33:50.220
wires, and often thin removable pad with
00:33:50.220 --> 00:33:52.729
unstructured bra, unpadded and wire
00:33:52.729 --> 00:33:55.922
free. And these do include straps and
00:33:55.922 --> 00:33:58.397
these are common definitions for
00:33:58.397 --> 00:34:06.701
bralette. CBP does not have a
00:34:06.701 --> 00:34:09.121
definition for the bralette. This is
00:34:09.121 --> 00:34:11.056
bra without standard bra components.
00:34:11.056 --> 00:34:13.206
They generally provide at least light
00:34:13.206 --> 00:34:15.389
suggest and are being embraced because
00:34:15.389 --> 00:34:18.317
of their comfort. Due to their
00:34:18.317 --> 00:34:20.194
unstructured nature, bralettes follow
00:34:20.194 --> 00:34:23.096
the contours of a woman's bust in a more
00:34:23.096 --> 00:34:25.381
natural way. Their sizing is different
00:34:25.381 --> 00:34:29.543
from traditional bras, and they're
00:34:29.543 --> 00:34:33.752
small, medium, large instead of 32A, 34B
00:34:33.752 --> 00:34:35.572
and so on. These are becoming so
00:34:35.572 --> 00:34:37.664
popular that bra companies that failed
00:34:37.664 --> 00:34:40.687
to embrace the trend have suffered
00:34:40.687 --> 00:34:43.387
significant decline in sales revenue.
00:34:43.387 --> 00:34:45.736
When I first started working with them,
00:34:45.736 --> 00:34:47.529
I was really quite confused, because I
00:34:47.529 --> 00:34:50.350
didn't think they offered much support
00:34:50.350 --> 00:34:53.309
and did they really provide the support
00:34:53.309 --> 00:35:00.707
needed to be in heading 6212, but they
00:35:00.707 --> 00:35:03.804
do in their own little way.
00:35:03.804 --> 00:35:06.221
What is a bralette exactly? Well,
00:35:06.221 --> 00:35:10.136
it can be many things. It can be a
00:35:10.136 --> 00:35:12.684
dainty easygoing alternative to a
00:35:12.684 --> 00:35:16.485
standard bra that functions as a bra.
00:35:16.485 --> 00:35:18.725
But many cases can be revealed to the
00:35:18.725 --> 00:35:21.461
public view a little bit, or even a lot.
00:35:21.461 --> 00:35:24.601
Like you have here. This style used to
00:35:24.601 --> 00:35:28.167
be worn by mainly teenagers and smaller
00:35:28.167 --> 00:35:31.520
busted women. But now women of all ages
00:35:31.520 --> 00:35:35.183
are embracing them somehow. We popped
00:35:35.183 --> 00:35:38.818
ahead.
00:35:38.818 --> 00:35:42.616
Even women larger chested women are
00:35:42.616 --> 00:35:45.092
wearing them. Sometimes for them, they
00:35:45.092 --> 00:35:47.121
might have some additional features,
00:35:47.121 --> 00:35:52.181
like cups, or closures, or more fabric.
00:35:52.181 --> 00:35:54.564
It seems bra let's are bigger on style
00:35:54.564 --> 00:35:57.276
than support, but times are changing,
00:35:57.276 --> 00:36:02.149
and women are not interested in
00:36:02.149 --> 00:36:03.936
suffering for comfort these days. Maybe
00:36:03.936 --> 00:36:10.999
they're not as concerned. Their main
00:36:10.999 --> 00:36:12.774
purpose must be support if they're
00:36:12.774 --> 00:36:20.930
classified in 6212. But they can, in
00:36:20.930 --> 00:36:24.207
addition add style to an outfit. The
00:36:24.207 --> 00:36:29.096
word duron is meaning strip and garment
00:36:29.096 --> 00:36:32.799
apprising of strip cloth. Today the
00:36:32.799 --> 00:36:34.466
term frequently refers to a garment that
00:36:34.466 --> 00:36:37.785
wraps around the women's bust, similar
00:36:37.785 --> 00:36:41.350
to a tube top but narrower. It's actual
00:36:41.350 --> 00:36:43.570
pull on style, sleeve-less, and off the
00:36:43.570 --> 00:36:45.811
shoulder. Both of these bras here were
00:36:45.811 --> 00:36:48.722
being advertised by an online bra
00:36:48.722 --> 00:36:50.577
retailer who does not sell regular
00:36:50.577 --> 00:36:52.827
clothing. There are only two ruling in
00:36:52.827 --> 00:36:57.818
cross that cover bandeau bra. That is
00:36:57.818 --> 00:37:03.642
N075316 and H88358. And I found most
00:37:03.642 --> 00:37:06.224
bandeau bras on the market today include
00:37:06.224 --> 00:37:09.151
support and shaping features such as
00:37:09.151 --> 00:37:13.732
removable or invisible straps, cups,
00:37:13.732 --> 00:37:22.036
heading, knit and ruching, and side
00:37:22.036 --> 00:37:26.205
boning, stays, under wire, side gather,
00:37:26.205 --> 00:37:31.029
tightly knit fabric, wider bottom bands.
00:37:31.029 --> 00:37:33.867
At first glance, these don't appear
00:37:33.867 --> 00:37:35.686
to offer that much support because you
00:37:35.686 --> 00:37:38.517
don't have the straps, but there are
00:37:38.517 --> 00:37:40.483
features here that are making these
00:37:40.483 --> 00:37:43.794
items supportive. And like I said, this
00:37:43.794 --> 00:37:47.223
one has some boning. It's got some Sony
00:37:47.223 --> 00:37:50.224
in elastic edges. It's lined. It's got
00:37:50.224 --> 00:37:53.782
silicone grippers. This particular one
00:37:53.782 --> 00:37:56.987
has very wide covered elastic bands at
00:37:56.987 --> 00:38:03.868
the top and bottom. Knit in review
00:38:03.868 --> 00:38:09.219
shaking [Rewriting] ruching. And this
00:38:09.219 --> 00:38:15.330
pointer is driving me crazy here.
00:38:15.330 --> 00:38:16.985
Let me see if I can calm this down.
00:38:16.985 --> 00:38:18.666
I don't know what's going on. My mouse
00:38:18.666 --> 00:38:37.118
is going crazy. So here, the garments
00:38:37.118 --> 00:38:40.665
pictured appear to be rather ambiguous.
00:38:40.665 --> 00:38:44.435
These are all bandeaus.
00:38:44.435 --> 00:38:46.237
Classification, each one of these
00:38:46.237 --> 00:38:48.498
garments would have to be evaluated on
00:38:48.498 --> 00:38:52.244
all of the factors presented. Ban doze
00:38:52.244 --> 00:38:55.107
are kind of like camisole in a sense
00:38:55.107 --> 00:38:57.244
they can be worn in several different
00:38:57.244 --> 00:39:00.096
ways and we're going to touch on how to
00:39:00.096 --> 00:39:01.837
classify ambiguous items in a moment.
00:39:01.837 --> 00:39:05.044
But here's our pointer again. I just
00:39:05.044 --> 00:39:06.902
pulled all of these 3 pictures off the
00:39:06.902 --> 00:39:09.241
Internet for fun. This one was actually
00:39:09.241 --> 00:39:11.931
called the bandeau bra, but it's being
00:39:11.931 --> 00:39:16.658
shown with shorts, which means she's
00:39:16.658 --> 00:39:18.730
wearing it out in public. Looks like
00:39:18.730 --> 00:39:20.953
it's a little bit wider than the bandeau
00:39:20.953 --> 00:39:24.325
bra we had on the previous slide. But
00:39:24.325 --> 00:39:25.602
we don't know what the exact features
00:39:25.602 --> 00:39:27.979
are. This one here looks more like the
00:39:27.979 --> 00:39:30.287
bandeau bra we had on the previous slide
00:39:30.287 --> 00:39:33.192
and it's quite narrow. And she's
00:39:33.192 --> 00:39:35.827
clearly wearing it in place of a bra.
00:39:35.827 --> 00:39:37.000
But she's also wearing it's on the
00:39:37.000 --> 00:39:39.918
street as a top with a modified cardigan
00:39:39.918 --> 00:39:43.803
and pants. I have no idea how this was
00:39:43.803 --> 00:39:46.346
designed, marketed, or sold, but I
00:39:46.346 --> 00:39:50.016
thought it was fascinating. And then we
00:39:50.016 --> 00:39:52.047
have the tube top. And it is born as
00:39:52.047 --> 00:39:54.856
outerwear with a pair of pants. But at
00:39:54.856 --> 00:39:57.176
first glance, all three of these
00:39:57.176 --> 00:39:58.884
garments seem to have a lot of
00:39:58.884 --> 00:40:03.051
similarities, don't they? I think as we
00:40:03.051 --> 00:40:08.274
finish up bras, I'll say a word about
00:40:08.274 --> 00:40:10.398
built in bras. And this is my wording
00:40:10.398 --> 00:40:17.204
here. I have HQ950658 for further
00:40:17.204 --> 00:40:19.450
reading, but built in bras designed as
00:40:19.450 --> 00:40:21.315
outerwear that also provides body
00:40:21.315 --> 00:40:25.558
support such as a yoga top, a swimsuit,
00:40:25.558 --> 00:40:28.742
and a dress with built in bras are not
00:40:28.742 --> 00:40:31.575
bras. They're outerwear. And these are
00:40:31.575 --> 00:40:33.400
a little more straightforward than some
00:40:33.400 --> 00:40:35.339
of the other garments that may be a
00:40:35.339 --> 00:40:38.101
little more abbreviated. But this
00:40:38.101 --> 00:40:41.675
drives home the concept that just
00:40:41.675 --> 00:40:43.435
because it has a bra built into it
00:40:43.435 --> 00:40:52.176
doesn't mean it is a bra. We're heading
00:40:52.176 --> 00:40:53.928
into the homestretch of this
00:40:53.928 --> 00:40:55.227
presentation here and I want to do take
00:40:55.227 --> 00:40:59.388
a moment to tell you that I appreciate
00:40:59.388 --> 00:41:00.773
you being here. And I appreciate you
00:41:00.773 --> 00:41:03.914
taking the time out of your day to spend
00:41:03.914 --> 00:41:06.458
some time on your own education. It's
00:41:06.458 --> 00:41:10.649
hard to do that because we're busy all
00:41:10.649 --> 00:41:12.393
the time and it's hard to pay attention
00:41:12.393 --> 00:41:15.358
to one topic for any length of time.
00:41:15.358 --> 00:41:17.241
But I'm proud of you for being here.
00:41:17.241 --> 00:41:19.510
And I'm proud that you are taking the
00:41:19.510 --> 00:41:22.285
time to dive into this topic with me.
00:41:22.285 --> 00:41:24.474
So thousand that we finished bras,
00:41:24.474 --> 00:41:25.834
we're going to tackle something a little
00:41:25.834 --> 00:41:27.959
bit more difficult. And we might just
00:41:27.959 --> 00:41:32.753
go on little bit more than an hour. I
00:41:32.753 --> 00:41:35.651
also wanted to, you know, tackle some of
00:41:35.651 --> 00:41:37.693
the questions we got about these items
00:41:37.693 --> 00:41:42.231
in the webinar. So if it's not a bra,
00:41:42.231 --> 00:41:45.361
but it's an upper body support garment,
00:41:45.361 --> 00:41:47.329
where would you classify it? So the
00:41:47.329 --> 00:41:50.438
bras are 6212.10. Clearly, we're not
00:41:50.438 --> 00:41:53.581
going to make it a girdle or corset.
00:41:53.581 --> 00:41:56.360
It's not a bra but it's not an upper
00:41:56.360 --> 00:41:59.903
body support garment. Could it be
00:41:59.903 --> 00:42:01.942
6212.90? Well, here, this is a good
00:42:01.942 --> 00:42:04.355
example of what we would call a shape
00:42:04.355 --> 00:42:06.726
wear tank that could be classified as a
00:42:06.726 --> 00:42:11.436
body supporting garment in subheading
00:42:11.436 --> 00:42:13.889
6212.90. It's advertised as being firm
00:42:13.889 --> 00:42:16.346
control and tightly knit fabric, great
00:42:16.346 --> 00:42:19.025
deal of spandex, and you can see how it
00:42:19.025 --> 00:42:22.308
really shapes the woman's mid-section.
00:42:22.308 --> 00:42:24.558
This was designed, marketed, and sold
00:42:24.558 --> 00:42:27.716
and used as a support garment only. It
00:42:27.716 --> 00:42:30.665
was not shown to display with underwear.
00:42:30.665 --> 00:42:33.397
It was not offered by a retailer that
00:42:33.397 --> 00:42:35.845
sells clothing. It had a lot of
00:42:35.845 --> 00:42:39.337
features that, you know, were convincing
00:42:39.337 --> 00:42:46.541
to make it a support garment in 6212.90.
00:42:46.541 --> 00:42:48.192
However, there are many garments
00:42:48.192 --> 00:42:51.531
that are, indeed, ambiguous, which means
00:42:51.531 --> 00:42:53.905
capable of being understood in two ways
00:42:53.905 --> 00:43:00.179
or more. This is a case study that I
00:43:00.179 --> 00:43:04.083
think we kind of already covered with
00:43:04.083 --> 00:43:06.666
object import specialist but I wanted to
00:43:06.666 --> 00:43:08.770
share with the trade. This is an
00:43:08.770 --> 00:43:11.859
ambiguous tank style knit garment and we
00:43:11.859 --> 00:43:14.647
had to decide if it was an underwear
00:43:14.647 --> 00:43:16.556
singlet or support tank and when I say
00:43:16.556 --> 00:43:18.649
singlet, I'm using the terminology from
00:43:18.649 --> 00:43:23.927
the tariff. But what I really mean is
00:43:23.927 --> 00:43:26.410
woman's undershirt. And you see here
00:43:26.410 --> 00:43:31.145
there's a huge difference in duty. If
00:43:31.145 --> 00:43:34.326
it's undershirt, it would be 32% duty.
00:43:34.326 --> 00:43:38.828
If it's a support tank, under 6212.90,
00:43:38.828 --> 00:43:45.506
you have 6.6% duty. So 6212 can be an
00:43:45.506 --> 00:43:48.521
enticing heading to want to use
00:43:48.521 --> 00:43:51.159
classified, because the duty rates are
00:43:51.159 --> 00:43:52.681
little bit lower. But we have to be
00:43:52.681 --> 00:43:54.335
strict about what goes there. So let's
00:43:54.335 --> 00:43:59.663
see what happened with this garment.
00:43:59.663 --> 00:44:01.952
This was designed as knit shape wear
00:44:01.952 --> 00:44:07.909
underwear tank. It's shape wear and
00:44:07.909 --> 00:44:09.774
underwear tank. Which one is it? I
00:44:09.774 --> 00:44:11.802
don't know, maybe it's both. This one
00:44:11.802 --> 00:44:14.020
had slightly different fiber content for
00:44:14.020 --> 00:44:15.917
the middle section and bust and the
00:44:15.917 --> 00:44:19.372
bottom, and some elasticized neckline,
00:44:19.372 --> 00:44:22.787
arm opening, and middle head change in
00:44:22.787 --> 00:44:24.929
the pattern. It was seamless,
00:44:24.929 --> 00:44:26.996
close-fitting and designed to fit slim
00:44:26.996 --> 00:44:28.944
to lower torso. Came in a variety of
00:44:28.944 --> 00:44:31.867
color. This is typical under wear color
00:44:31.867 --> 00:44:34.151
and it was also being sold in the
00:44:34.151 --> 00:44:35.988
intimates department.
00:44:35.988 --> 00:44:39.493
We got a sample at this stage, but
00:44:39.493 --> 00:44:41.539
no further documentation. And we really
00:44:41.539 --> 00:44:43.896
didn't get any information about how it
00:44:43.896 --> 00:44:47.231
was designed, marketed, and sold. We
00:44:47.231 --> 00:44:49.802
didn't have any hand tags, no packaging,
00:44:49.802 --> 00:44:52.804
or any advertising at this point. We
00:44:52.804 --> 00:44:58.213
did get some of that information. It
00:44:58.213 --> 00:45:00.150
was interesting, but what we really
00:45:00.150 --> 00:45:03.805
fountain, we tried the garment on a live
00:45:03.805 --> 00:45:07.274
model and found the garment was not
00:45:07.274 --> 00:45:09.609
tight-fitting nor substantially
00:45:09.609 --> 00:45:13.933
supporting in any way. Although it was
00:45:13.933 --> 00:45:13.965
close-fitting and clung to the body in
00:45:13.965 --> 00:45:17.983
the manner of an undershirt. We didn't
00:45:17.983 --> 00:45:21.023
find shaping or support for mid-area,
00:45:21.023 --> 00:45:23.023
and the garment really had no bust
00:45:23.023 --> 00:45:25.051
support at all. In addition, we found a
00:45:25.051 --> 00:45:27.523
companion piece which was a short style
00:45:27.523 --> 00:45:29.849
under pant with the same fabric and
00:45:29.849 --> 00:45:31.619
fiber content and I think the question
00:45:31.619 --> 00:45:34.782
on that one, too, was it a girdle? But
00:45:34.782 --> 00:45:38.318
like the undershirt, neither garment
00:45:38.318 --> 00:45:41.120
were found to be 6212, because they
00:45:41.120 --> 00:45:43.730
weren't sufficiently supportive.
00:45:43.730 --> 00:45:46.053
But it wasn't easy to come to this
00:45:46.053 --> 00:45:48.407
conclusion. We had to look at all the
00:45:48.407 --> 00:45:50.566
features of the garments, all of the
00:45:50.566 --> 00:45:53.336
documentation, and, you know, make a
00:45:53.336 --> 00:45:57.579
fair judgment call. How do we classify
00:45:57.579 --> 00:45:59.360
ambiguous garments? I'm going to give
00:45:59.360 --> 00:46:01.609
you some tips. You want to look at the
00:46:01.609 --> 00:46:03.533
garment itself. Determine what the
00:46:03.533 --> 00:46:06.244
physical features of the garment are.
00:46:06.244 --> 00:46:08.627
Write them down. Are those features
00:46:08.627 --> 00:46:11.089
practical? Does the fabric, design and
00:46:11.089 --> 00:46:12.799
styling of the construction of the
00:46:12.799 --> 00:46:13.878
garment make it suitable for the
00:46:13.878 --> 00:46:16.886
intended purpose? Does the garment have
00:46:16.886 --> 00:46:18.648
companion pieces? How is the garment
00:46:18.648 --> 00:46:21.331
designed, marketed, sold, and used?
00:46:21.331 --> 00:46:22.914
Actually look at the marketing, the
00:46:22.914 --> 00:46:25.334
advertising, professional and sales
00:46:25.334 --> 00:46:27.363
environment information, catalogs,
00:46:27.363 --> 00:46:32.350
Internet. Here's another example.
00:46:32.350 --> 00:46:35.964
6109, 6114, 6212, it could be any of the
00:46:35.964 --> 00:46:37.583
3. Consider which department the
00:46:37.583 --> 00:46:39.765
garment is sold in. Look at the actual
00:46:39.765 --> 00:46:42.770
packaging, the hand tags, the displays,
00:46:42.770 --> 00:46:45.153
the nature of the importer's business,
00:46:45.153 --> 00:46:49.229
what kind of retailer is the importer?
00:46:49.229 --> 00:46:51.715
Are they an established I know the
00:46:51.715 --> 00:46:54.203
minute apparel company? Do they sell
00:46:54.203 --> 00:46:57.578
outerwear? And this was off Amazon, it
00:46:57.578 --> 00:47:02.032
was actually under section for lingerie
00:47:02.032 --> 00:47:04.381
and bra and sports bra. And it was
00:47:04.381 --> 00:47:07.181
designed in typical fashion as couple of
00:47:07.181 --> 00:47:10.080
different things. Sports bra, removable
00:47:10.080 --> 00:47:13.654
padded yoga tank top, sleeve-less
00:47:13.654 --> 00:47:17.160
fitness work out running crop top.
00:47:17.160 --> 00:47:19.084
Well, we don't have any details,
00:47:19.084 --> 00:47:22.368
because I don't have it in front of me.
00:47:22.368 --> 00:47:24.332
But I would have to tell you that
00:47:24.332 --> 00:47:26.259
there's too much body conversation for
00:47:26.259 --> 00:47:29.318
this to be a bra in 6212. It's more
00:47:29.318 --> 00:47:31.787
along the lines of outerwear with a
00:47:31.787 --> 00:47:36.377
built-in bra. I suggest referring it to
00:47:36.377 --> 00:47:38.347
the National Import Specialist that
00:47:38.347 --> 00:47:41.311
handles. I think 6114, because it
00:47:41.311 --> 00:47:43.031
doesn't reach to the taste, it would be
00:47:43.031 --> 00:47:45.459
considered a top. Because the
00:47:45.459 --> 00:47:49.027
Victoria's Secret court case tell us if
00:47:49.027 --> 00:47:51.654
the degree of coverage is more than that
00:47:51.654 --> 00:47:55.485
provided by a brassiere, as the term is
00:47:55.485 --> 00:48:00.063
ordinarily used, and the coverage is
00:48:00.063 --> 00:48:02.983
sufficient that the garment is designed
00:48:02.983 --> 00:48:05.426
to be worn in public without layers in
00:48:05.426 --> 00:48:08.925
the garment, just because an item may be
00:48:08.925 --> 00:48:11.079
called a sports bra does not mean it is
00:48:11.079 --> 00:48:14.931
one for custom's purposes.
00:48:14.931 --> 00:48:17.929
Here is a listing of what the
00:48:17.929 --> 00:48:21.169
Carborundum factors are according to the
00:48:21.169 --> 00:48:22.729
Court case. And it's basically the
00:48:22.729 --> 00:48:25.055
legal basis for what we just discussed
00:48:25.055 --> 00:48:27.760
previously. If you need additional
00:48:27.760 --> 00:48:29.856
information, you know, for ambiguous
00:48:29.856 --> 00:48:32.369
garment, you will need additional
00:48:32.369 --> 00:48:33.363
information beyond an invoice
00:48:33.363 --> 00:48:36.000
description for these ambiguous
00:48:36.000 --> 00:48:37.347
garments. There are various rulings
00:48:37.347 --> 00:48:41.134
that cite the Carborundum Factors. I
00:48:41.134 --> 00:48:42.939
have a few in my notes. But it's
00:48:42.939 --> 00:48:45.724
actually easier for you just to go into
00:48:45.724 --> 00:48:48.165
cross if type in Carborundum factors.
00:48:48.165 --> 00:48:49.753
Those rulings will come up. And you
00:48:49.753 --> 00:48:52.072
can see kind of like when you need to
00:48:52.072 --> 00:48:54.643
apply them or how they have been applied
00:48:54.643 --> 00:48:58.258
in the past.
00:48:58.258 --> 00:49:00.325
So I always like to end on a
00:49:00.325 --> 00:49:03.145
positive note or confusing note. So
00:49:03.145 --> 00:49:06.774
let's do this one here. There are so
00:49:06.774 --> 00:49:09.576
many perplexing garments these days
00:49:09.576 --> 00:49:11.790
being worn in various ways.
00:49:11.790 --> 00:49:16.420
Headquarters ruling 954488 way back in
00:49:16.420 --> 00:49:18.399
1993 classified a decorated brassiere.
00:49:18.399 --> 00:49:22.482
It said that although serving as a body
00:49:22.482 --> 00:49:25.182
support garment, a brassiere may be worn
00:49:25.182 --> 00:49:27.471
as outerwear. And that it's now
00:49:27.471 --> 00:49:29.584
acceptable to let brassieres that have
00:49:29.584 --> 00:49:33.614
been embellished show under outer wear
00:49:33.614 --> 00:49:35.515
or even be worn by themselves. Well,
00:49:35.515 --> 00:49:38.212
this picture is not related to that
00:49:38.212 --> 00:49:39.097
headquarters ruling. This is something
00:49:39.097 --> 00:49:41.472
I came up with to talk about. But let's
00:49:41.472 --> 00:49:43.962
talk about this for a moment and ask
00:49:43.962 --> 00:49:46.244
ourselves some questions. Is this item
00:49:46.244 --> 00:49:48.492
treated as foundational wear in the
00:49:48.492 --> 00:49:51.633
industry? Was it made in a bra factory?
00:49:51.633 --> 00:49:53.846
Does it have bra support features such
00:49:53.846 --> 00:49:57.080
as cups, under wire? Or does it have
00:49:57.080 --> 00:50:02.334
strings in the back on the neck?
00:50:02.334 --> 00:50:04.719
Does it support its primary purpose?
00:50:04.719 --> 00:50:09.301
Is the outer wear aspect equally
00:50:09.301 --> 00:50:11.315
competing to the body support function?
00:50:11.315 --> 00:50:14.226
And that's from the case. Is the outer
00:50:14.226 --> 00:50:16.674
way aspect equally competing with the
00:50:16.674 --> 00:50:19.348
body wear function? I know, the ads are
00:50:19.348 --> 00:50:21.251
great. I actually had to put this
00:50:21.251 --> 00:50:23.735
picture up, because she looks so fab
00:50:23.735 --> 00:50:26.177
less with 6 pack abs and she can wear
00:50:26.177 --> 00:50:28.208
whatever she wants. Can we call this
00:50:28.208 --> 00:50:30.439
item outerwear? Does it provide enough
00:50:30.439 --> 00:50:32.765
coverage? I don't know. Is this a bra
00:50:32.765 --> 00:50:37.120
in 6212? Is it a knit top in 6114? Is
00:50:37.120 --> 00:50:41.318
it a swim top at 6112? And here's the
00:50:41.318 --> 00:50:44.184
real question. Do you wear this to work
00:50:44.184 --> 00:50:46.744
or is it just for Coachella? I don't
00:50:46.744 --> 00:50:48.085
know.
00:50:48.085 --> 00:50:49.711
I love to see what you all say when
00:50:49.711 --> 00:50:52.875
I look at, I'll get a transcript of your
00:50:52.875 --> 00:50:54.689
comments so, someone is going to wear it
00:50:54.689 --> 00:50:57.771
to work. [Laughter] that's a good one.
00:50:57.771 --> 00:51:00.791
So if you find yourself struggling with
00:51:00.791 --> 00:51:03.073
classifying garments like the last one,
00:51:03.073 --> 00:51:05.289
get a hold of these court cases and read
00:51:05.289 --> 00:51:08.088
them, really. Read them in bits if you
00:51:08.088 --> 00:51:10.762
have to. They really help explain some
00:51:10.762 --> 00:51:13.204
of the concepts behind body-supporting
00:51:13.204 --> 00:51:14.790
garments versus tops.
00:51:14.790 --> 00:51:16.861
I can't read them all at once, but
00:51:16.861 --> 00:51:19.466
every time I do go back and I read
00:51:19.466 --> 00:51:22.401
sections, it's really helpful. If you
00:51:22.401 --> 00:51:25.914
can't find these online, or get them,
00:51:25.914 --> 00:51:31.872
you know, easily, just send me or my
00:51:31.872 --> 00:51:33.637
associate Lisa a message, and we will
00:51:33.637 --> 00:51:37.190
get a copy of those court cases to you
00:51:37.190 --> 00:51:39.648
via email. This is our contact
00:51:39.648 --> 00:51:44.797
information. Email is always the best,
00:51:44.797 --> 00:51:47.652
because if I'm not in, Lisa can get back
00:51:47.652 --> 00:51:49.518
to you. And I do want to take a moment
00:51:49.518 --> 00:51:53.763
to thank my team that helped with this
00:51:53.763 --> 00:51:59.306
webinar in every way, Sandra Walia,
00:51:59.306 --> 00:52:14.903
Lynne banks, Fung King Kong. And Amy.
00:52:14.903 --> 00:52:16.837
You can raise your hand for microphone
00:52:16.837 --> 00:52:19.308
access and I'll try to turn it on. Or
00:52:19.308 --> 00:52:21.486
you can type it in the chat box.
00:52:21.486 --> 00:52:23.436
Thank you for your applause. Thank
00:52:23.436 --> 00:52:27.588
you.
00:52:27.588 --> 00:52:29.495
>> So Karen you had a few questions
00:52:29.495 --> 00:52:34.081
that came up. We won't unmute people
00:52:34.081 --> 00:52:36.111
with the raised hand function but they
00:52:36.111 --> 00:52:38.334
can type in the chat box. Couple of
00:52:38.334 --> 00:52:40.039
easier questions, please clarify
00:52:40.039 --> 00:52:41.915
specifics about work out bra. Some are
00:52:41.915 --> 00:52:46.069
being used as outer wear. Will they be
00:52:46.069 --> 00:52:47.850
6114 even if it has support and pads? I
00:52:47.850 --> 00:52:50.006
think you touched on this in some of the
00:52:50.006 --> 00:52:51.437
later slides.
00:52:51.437 --> 00:52:52.831
>> KAREN SIKORSKI: I didn't quite
00:52:52.831 --> 00:52:54.548
catch the whole question. Do you think
00:52:54.548 --> 00:52:56.146
you can repeat it a little bit more
00:52:56.146 --> 00:52:57.934
slowly?
00:52:57.934 --> 00:52:59.578
>> Sure. Please clarify specifics
00:52:59.578 --> 00:53:01.831
about work out bra. Some are being used
00:53:01.831 --> 00:53:06.061
as outerwear. Will they be 6114 even if
00:53:06.061 --> 00:53:11.822
it has support and pads?
00:53:11.822 --> 00:53:12.217
>> KAREN SIKORSKI: You know,
00:53:12.217 --> 00:53:14.496
there's so many different variations of
00:53:14.496 --> 00:53:16.526
work out bras. I am aware of what's out
00:53:16.526 --> 00:53:19.099
there on the market. And it's crazy.
00:53:19.099 --> 00:53:22.855
And women are wearing what we would, in
00:53:22.855 --> 00:53:29.085
the past, be called sports bra you wear
00:53:29.085 --> 00:53:31.670
a tank top over. Now they're wearing
00:53:31.670 --> 00:53:33.812
them as the top, because a lot of women
00:53:33.812 --> 00:53:45.168
wear a lot of high waisted pants. And I
00:53:45.168 --> 00:53:48.416
actually had 3 or 4 of them come from
00:53:48.416 --> 00:53:54.970
the importers. And 3 of them turned out
00:53:54.970 --> 00:53:56.718
to be tops and one of them turned out to
00:53:56.718 --> 00:53:58.712
be a bra. It just depends. That's why
00:53:58.712 --> 00:54:02.957
I said when they're ambiguous like this,
00:54:02.957 --> 00:54:04.630
you have to look at the actual physical
00:54:04.630 --> 00:54:06.443
feature and then you have to look at the
00:54:06.443 --> 00:54:08.125
marketing and practicality, et cetera.
00:54:08.125 --> 00:54:11.046
There is some subjectivity there and
00:54:11.046 --> 00:54:13.033
I'm perfectly aware of this. And I look
00:54:13.033 --> 00:54:14.839
at things online all the time, and I
00:54:14.839 --> 00:54:18.196
think to myself, oh my, how would I
00:54:18.196 --> 00:54:20.277
classify that? But you have to dig
00:54:20.277 --> 00:54:25.152
deep. And like I said, if you have a
00:54:25.152 --> 00:54:29.651
question, you can always send it in for
00:54:29.651 --> 00:54:32.588
binding ruling. We have 30-day turn
00:54:32.588 --> 00:54:34.515
around. I hope that helps.
00:54:34.515 --> 00:54:36.805
>> Another convention. How does
00:54:36.805 --> 00:54:39.585
athletic compression apparel fit into
00:54:39.585 --> 00:54:42.032
6212 for men or women? Can short or
00:54:42.032 --> 00:54:45.803
long sheaf tops or bottoms be included?
00:54:45.803 --> 00:54:46.956
>> KAREN SIKORSKI: Yes, they can.
00:54:46.956 --> 00:54:49.794
I did not cover that in the webinar, but
00:54:49.794 --> 00:54:52.620
we have covered it a bit in the past.
00:54:52.620 --> 00:54:54.080
There are shirts that have been
00:54:54.080 --> 00:54:57.080
determined to be designed for
00:54:57.080 --> 00:54:59.537
compression purposes. And they have
00:54:59.537 --> 00:55:02.244
special features built in. And
00:55:02.244 --> 00:55:04.384
something like for example, a posture
00:55:04.384 --> 00:55:07.035
shirt which I didn't know existed. It
00:55:07.035 --> 00:55:10.195
has certain specialized features to help
00:55:10.195 --> 00:55:13.250
support posture. And you wouldn't wear
00:55:13.250 --> 00:55:20.152
it as a typical outerwear type of thing.
00:55:20.152 --> 00:55:22.809
It's got unique features that make it
00:55:22.809 --> 00:55:24.523
support its primary purpose. So you
00:55:24.523 --> 00:55:27.038
can take a look and see what's across
00:55:27.038 --> 00:55:29.511
there by putting in the terminology
00:55:29.511 --> 00:55:33.970
compression wear, outerwear. But
00:55:33.970 --> 00:55:36.384
there's a swim shirt we did. I didn't
00:55:36.384 --> 00:55:38.100
do it, but someone else did. And I
00:55:38.100 --> 00:55:42.657
think there were some shirts with some,
00:55:42.657 --> 00:55:44.849
maybe not weights, but, yeah, maybe
00:55:44.849 --> 00:55:47.205
there were weights in there. There have
00:55:47.205 --> 00:55:49.873
been some articles for athletic wear
00:55:49.873 --> 00:55:51.527
that have been classified as compression
00:55:51.527 --> 00:55:57.457
wear under very specific circumstances.
00:55:57.457 --> 00:55:58.944
>> Okay. Another convention. Are
00:55:58.944 --> 00:56:02.348
men's JFO-OCC straps/classified
00:56:02.348 --> 00:56:05.332
supporters classified under 6212?
00:56:05.332 --> 00:56:06.183
>> KAREN SIKORSKI: Yes, they are.
00:56:06.183 --> 00:56:08.093
I'm pretty sure that the word JFO-OCC
00:56:08.093 --> 00:56:11.042
strap was even mentioned in the
00:56:11.042 --> 00:56:16.297
explanatory notes if I'm correct.
00:56:16.297 --> 00:56:18.684
>> Okay, great. Is there a link we
00:56:18.684 --> 00:56:22.810
can follow to be 6114 or bra or rib
00:56:22.810 --> 00:56:25.617
cage? Or maybe this is not a feature we
00:56:25.617 --> 00:56:30.669
can follow?
00:56:30.669 --> 00:56:32.377
>> KAREN SIKORSKI: Oh, is there a
00:56:32.377 --> 00:56:35.874
length we can follow (reading chat) it's
00:56:35.874 --> 00:56:37.299
one of the things we can follow, because
00:56:37.299 --> 00:56:39.748
remember, we talked about bras being
00:56:39.748 --> 00:56:41.684
long-line bras that come further down on
00:56:41.684 --> 00:56:47.941
the body. So you look at -- those are
00:56:47.941 --> 00:56:51.057
traditional. Those long-line bras. Now
00:56:51.057 --> 00:56:53.984
they're making long-line sports bras.
00:56:53.984 --> 00:56:57.402
And then the other thing is, too, there
00:56:57.402 --> 00:57:00.382
are no hard-and-fast rules, I guess, is
00:57:00.382 --> 00:57:04.414
kind of what you're asking. You can
00:57:04.414 --> 00:57:08.120
always measure and compare. And
00:57:08.120 --> 00:57:11.116
sometimes our rulings actually will give
00:57:11.116 --> 00:57:12.815
you measurements like for example, when
00:57:12.815 --> 00:57:16.306
I was looking at bandeau bras, I noticed
00:57:16.306 --> 00:57:19.000
that the bandeau bras had measurements
00:57:19.000 --> 00:57:22.892
of the length of the bandeaus, which is
00:57:22.892 --> 00:57:24.723
really good to know, because the one I
00:57:24.723 --> 00:57:27.269
was looking at was very similar to the
00:57:27.269 --> 00:57:30.626
bandeau bras that custom has classified
00:57:30.626 --> 00:57:32.464
in the past, and they were about 5
00:57:32.464 --> 00:57:35.158
inches long. But, no, there is no
00:57:35.158 --> 00:57:36.621
hard-and-fast rules. Sorry.
00:57:36.621 --> 00:57:38.919
>> Okay. Next question you might
00:57:38.919 --> 00:57:41.195
see it too. It says I believe this was
00:57:41.195 --> 00:57:42.883
mentioned but in your opinion, would you
00:57:42.883 --> 00:57:45.161
say fashion trends make classifying more
00:57:45.161 --> 00:57:47.419
complicated? Or would it be easier
00:57:47.419 --> 00:57:51.957
because of an item's true intention?
00:57:51.957 --> 00:57:54.424
>> KAREN SIKORSKI: I think it's a
00:57:54.424 --> 00:57:58.527
double question, really. Would fashion
00:57:58.527 --> 00:58:00.222
trends making classification more
00:58:00.222 --> 00:58:02.035
complicated? Of course it does. That's
00:58:02.035 --> 00:58:05.514
the thing. Fashion is always changing.
00:58:05.514 --> 00:58:07.717
But what we have to remember for
00:58:07.717 --> 00:58:10.447
classification purposes is that we have
00:58:10.447 --> 00:58:12.892
to think of it in terms of the tariff
00:58:12.892 --> 00:58:16.298
and not necessarily fashion. The two
00:58:16.298 --> 00:58:20.401
can intersect, but for custom's
00:58:20.401 --> 00:58:22.118
purposes, like for example, we talked
00:58:22.118 --> 00:58:26.117
about lace earlier, and you know, a lot
00:58:26.117 --> 00:58:27.896
of times people in the industry will
00:58:27.896 --> 00:58:30.243
say, oh, this is lace. Well, for
00:58:30.243 --> 00:58:33.328
custom's purposes, it's not. You know?
00:58:33.328 --> 00:58:37.190
S and because the tariff defines things,
00:58:37.190 --> 00:58:42.377
and we have like ruling history and
00:58:42.377 --> 00:58:44.287
court cases that define things, we
00:58:44.287 --> 00:58:48.999
can't, yeah, fashion definitely makes
00:58:48.999 --> 00:58:51.268
classification complicated.
00:58:51.268 --> 00:58:56.933
But items' intention and usage are
00:58:56.933 --> 00:59:00.494
important as well. If something is
00:59:00.494 --> 00:59:05.340
claimed to be used as a bra, but it has
00:59:05.340 --> 00:59:11.230
virtually no support, is it really a
00:59:11.230 --> 00:59:14.153
bra? You know? And when the Court
00:59:14.153 --> 00:59:17.659
tells us that support is the paramount
00:59:17.659 --> 00:59:20.648
function of heading 6212, like that
00:59:20.648 --> 00:59:22.942
undershirt we discussed earlier, you
00:59:22.942 --> 00:59:25.294
know, maybe somebody was planning to
00:59:25.294 --> 00:59:29.610
wear that as a support tank. But we
00:59:29.610 --> 00:59:34.675
found that it didn't have enough -- its
00:59:34.675 --> 00:59:37.336
true purpose was not as a support tank.
00:59:37.336 --> 00:59:39.814
We had to make a judgment call that it
00:59:39.814 --> 00:59:42.199
was not supportive enough to be a
00:59:42.199 --> 00:59:43.751
support tank. It's complicated. Trust
00:59:43.751 --> 00:59:46.966
me, I understand. (Chuckles softly).
00:59:46.966 --> 00:59:48.491
>> Another question. Are there any
00:59:48.491 --> 00:59:50.396
helpful rulings for guidance when
00:59:50.396 --> 00:59:54.999
deciding a bra let or bra is 6212 or top
00:59:54.999 --> 01:00:00.972
of 6114?
01:00:00.972 --> 01:00:01.827
>> KAREN SIKORSKI: You know, I had
01:00:01.827 --> 01:00:05.746
to do a lot of education for myself on
01:00:05.746 --> 01:00:07.520
bralettes when I started looking at
01:00:07.520 --> 01:00:10.346
them. I cannot recall off the top of my
01:00:10.346 --> 01:00:13.438
head if we actually used the word
01:00:13.438 --> 01:00:17.775
"bralette" or any of my predecessors or
01:00:17.775 --> 01:00:22.409
headquarters attorney used the word
01:00:22.409 --> 01:00:24.313
bralette or not. But you can always
01:00:24.313 --> 01:00:26.505
type that word into the search bar and
01:00:26.505 --> 01:00:31.289
see if anything comes up. I can't
01:00:31.289 --> 01:00:33.509
recall. You know, you can follow-up
01:00:33.509 --> 01:00:35.826
with me if you want via email. We can
01:00:35.826 --> 01:00:40.242
discuss this over the phone or further.
01:00:40.242 --> 01:00:42.322
I have, you know, a lot of information
01:00:42.322 --> 01:00:46.868
that falls on bralettes, but I had some
01:00:46.868 --> 01:00:48.959
really good rulings on bralettes, I
01:00:48.959 --> 01:00:50.291
probably would have posted them for you.
01:00:50.291 --> 01:00:53.575
But we can discuss further if you like.
01:00:53.575 --> 01:00:55.892
>> Okay. Someone noted bralette
01:00:55.892 --> 01:00:57.487
comes up in the cross certainly. They
01:00:57.487 --> 01:01:00.107
noted that in the chat box. Question,
01:01:00.107 --> 01:01:04.035
if a knit sports bra has a shelf bra, is
01:01:04.035 --> 01:01:07.219
it classified in 6114?
01:01:07.219 --> 01:01:11.144
>> KAREN SIKORSKI: Knit sports bra
01:01:11.144 --> 01:01:20.668
has a shelf bra, is it 6114? I have not
01:01:20.668 --> 01:01:26.509
seen one. But I have seen items that
01:01:26.509 --> 01:01:33.845
have been sports bras that -- sports
01:01:33.845 --> 01:01:38.299
bras with a shelf bra. Hmm... I can't
01:01:38.299 --> 01:01:42.596
say. That's perplexing question. I
01:01:42.596 --> 01:01:45.423
have to ask you to put in a request for
01:01:45.423 --> 01:01:47.560
binding ruling, honestly, because I have
01:01:47.560 --> 01:01:50.109
not seen that. I have seen sports bras
01:01:50.109 --> 01:01:54.096
that are completely knit. And they're
01:01:54.096 --> 01:01:56.159
absolutely 100% knit. I've
01:01:56.159 --> 01:02:01.322
deconstucted. I've actually done origin
01:02:01.322 --> 01:02:03.126
ruling on them and there's interesting
01:02:03.126 --> 01:02:05.957
different knit patterns in those bras
01:02:05.957 --> 01:02:07.961
that provide support. But I have not
01:02:07.961 --> 01:02:12.066
seen a shelf bra. I have not seen shelf
01:02:12.066 --> 01:02:15.561
bra in anything in a while, honestly.
01:02:15.561 --> 01:02:17.497
>> Okay. That's pretty much it.
01:02:17.497 --> 01:02:18.875
There was a question that came in
01:02:18.875 --> 01:02:20.524
earlier, couple of them about when the
01:02:20.524 --> 01:02:24.855
new apparel terminology ICP will be
01:02:24.855 --> 01:02:27.530
available? I checked with branch chief
01:02:27.530 --> 01:02:32.636
Debbie Manalucci and she said it should
01:02:32.636 --> 01:02:35.764
be available with sign off in a next few
01:02:35.764 --> 01:02:36.625
months.
01:02:36.625 --> 01:02:37.621
>> KAREN SIKORSKI: That's awesome.
01:02:37.621 --> 01:02:38.967
We've been working on that publication
01:02:38.967 --> 01:02:40.997
for quite some time and it's old. But
01:02:40.997 --> 01:02:43.032
that's great to hear, Sandra. Thank
01:02:43.032 --> 01:02:43.605
you.
01:02:43.605 --> 01:02:44.897
>> I think that's all for the
01:02:44.897 --> 01:02:46.081
questions.
01:02:46.081 --> 01:02:46.936
>> KAREN SIKORSKI: Okay. Awesome.
01:02:46.936 --> 01:02:51.170
Thank you, everybody.
01:02:51.170 --> 01:02:53.157
>> We hope you found today's webinar
01:02:53.157 --> 01:02:55.486
informative. The Continuing Education
01:02:55.486 --> 01:02:58.134
credit code was placed in the WebEx chat
01:02:58.134 --> 01:03:00.905
box during the presentation. And it
01:03:00.905 --> 01:03:03.026
will be emailed to everyone within 48
01:03:03.026 --> 01:03:05.894
hours. Today's webinar will be posted
01:03:05.894 --> 01:03:09.264
on CBP.gov under the trade outreach
01:03:09.264 --> 01:03:12.178
webinars in the coming weeks. We thank
01:03:12.178 --> 01:03:14.557
you for joining us today. And this

01:03:15.774 --> 01:03:15.774
afternoon, everyone.