WEBVTT 00:00:03.000 --> 00:00:08.366 >> Good afternoon, I am Chrissi Guth with 00:00:08.366 --> 00:00:11.621 CDB office of trade relations. Today's webinar 00:00:11.621 --> 00:00:19.497 is on the loose fitting blouses 2022 HTS 00:00:19.497 --> 00:00:23.557 us changes to headings 6106 webinar. 00:00:23.557 --> 00:00:25.001 Please be mindful that you will be 00:00:25.001 --> 00:00:31.574 on mute during the presentation, 00:00:31.574 --> 00:00:35.686 therefore we ask that you please submit any questions you have in the chat feature. 00:00:35.686 --> 00:00:37.886 Now I would like to pass it over to national import specialist, 00:00:37.886 --> 00:00:41.675 Antoinette Peek-Williams. 00:00:41.675 --> 00:00:47.052 >>ANTOINETTE: Thank you, Chrissy. 00:00:47.052 --> 00:00:53.577 Good afternoon, good morning for some. 00:00:53.577 --> 00:00:56.332 Before we start, I would just like to say I am battling a cold, I apologize in advance 00:00:56.332 --> 00:00:59.095 for my sore throat or coughing. I ask 00:00:59.095 --> 00:01:03.563 for your grace during this webinar. It 00:01:03.563 --> 00:01:05.441 is good information, and I want to get it out really 00:01:05.441 --> 00:01:07.361 in our webinar series. So I have my 00:01:07.361 --> 00:01:10.277 team, and hopefully enough to get me 00:01:10.277 --> 00:01:12.717 through and it won't be too bad. 00:01:12.717 --> 00:01:16.669 My name is Antoinette 00:01:16.669 --> 00:01:17.841 Peek-Williams, I am national import specialist 00:01:17.841 --> 00:01:24.944 361. I handle women's knit shorts, 00:01:24.944 --> 00:01:34.874 pants, and skirts, and hitting 6104. 00:01:34.874 --> 00:01:39.886 Shirts and blouses in heading 106, T-shirts tank tops and similar garments in headings 6109. 00:01:39.886 --> 00:01:42.637 Finally, tops, bodysuits, jumpers, and jumpsuits 00:01:42.637 --> 00:01:42.638 in heading 6114. 00:01:42.638 --> 00:01:51.578 Before we go any further, we need 00:01:51.578 --> 00:01:54.406 to advise everybody of the mission 00:01:54.406 --> 00:02:01.398 statement. That is, to protect the 00:02:01.398 --> 00:02:04.322 American people, safeguard our borders, and enhance the nation's economic prosperity. 00:02:04.322 --> 00:02:06.197 The office of trade mission statement, 00:02:06.197 --> 00:02:11.530 which is what the NCSC branch is under. 00:02:11.530 --> 00:02:13.086 The office of trade facilitates 00:02:13.086 --> 00:02:18.936 legitimate trade, and forces U.S. loss, 00:02:18.936 --> 00:02:21.666 and protects the American economy to ensure consumer safety and to 00:02:21.666 --> 00:02:23.202 create a level playing field for 00:02:23.202 --> 00:02:32.643 American businesses. Here's our 00:02:32.643 --> 00:02:36.467 disclaimer, I've highlighted the important parts 00:02:36.467 --> 00:02:40.771 that you can glaze over. We do our best 00:02:40.771 --> 00:02:42.443 to give you accurate and timely information. 00:02:42.443 --> 00:02:49.524 Sometimes things can and do change, 00:02:49.524 --> 00:02:55.539 please don't solely rely on the information in this webinar 00:02:55.539 --> 00:02:59.658 to classify your goods. If you do, it might not be considered reasonable care. 00:02:59.658 --> 00:03:03.844 If you have any questions regarding classification of your 00:03:03.844 --> 00:03:04.463 garment, your best option would be to write for binding ruling. 00:03:04.463 --> 00:03:04.464 00:03:04.464 --> 00:03:13.738 The images disclaimer, in a 00:03:13.738 --> 00:03:20.968 nutshell, photos of samples and pictures 00:03:20.968 --> 00:03:24.802 of items subject to public ruling are acceptable. 00:03:24.802 --> 00:03:27.697 Unless the imported request of confidentiality, 00:03:27.697 --> 00:03:31.474 or it is subject to a trade secret. 00:03:31.474 --> 00:03:37.188 Get a binding ruling, electronic 00:03:37.188 --> 00:03:41.969 rulings are the way to go. You can 00:03:41.969 --> 00:03:45.780 access the EE ruling template at the 00:03:45.780 --> 00:03:47.821 site listed on the screen. I strongly recommend 00:03:47.821 --> 00:03:49.372 that you submit your rulings 00:03:49.372 --> 00:03:52.140 electronically. They are quicker than 00:03:52.140 --> 00:03:57.812 paper-based rulings. They already are in 00:03:57.812 --> 00:04:04.598 the ruling system so they don't have to be manually created. 00:04:04.598 --> 00:04:04.599 00:04:04.599 --> 00:04:08.982 For peril, most times if you have samples that are required, you can still use it. 00:04:08.982 --> 00:04:12.122 You can submit samples even if you file the request electronically. 00:04:12.122 --> 00:04:13.834 Just enter the information into the ruling template 00:04:13.834 --> 00:04:17.295 like you would normally do. Receive an 00:04:17.295 --> 00:04:23.127 email that tells you where to send the sample. 00:04:23.127 --> 00:04:25.773 This part is very important, once you receive the email, please send the samples right away 00:04:25.773 --> 00:04:27.254 in the fastest way possible so the 00:04:27.254 --> 00:04:29.692 rulings can be completed on time. 00:04:29.692 --> 00:04:36.520 My samples come to the World Trade 00:04:36.520 --> 00:04:39.267 Center, I don't know if there is another address that is given, 00:04:39.267 --> 00:04:44.815 it might be backstreet but any rulings 00:04:44.815 --> 00:04:49.277 that are sent to me, I prefer my samples to be sent to one World Trade Center. 00:04:49.277 --> 00:04:49.278 00:04:49.278 --> 00:04:50.513 If your company is a trade compliance partner, certified for both 00:04:50.513 --> 00:04:55.797 TTAPTS and ISI, please email your 00:04:55.797 --> 00:04:58.897 samples next day. And that is a please. 00:04:58.897 --> 00:04:59.917 Because your rulings have a shorter 00:04:59.917 --> 00:05:05.251 timeframe so the sooner we received the 00:05:05.251 --> 00:05:07.661 sample, the better we are and the better we can get your ruling out 00:05:07.661 --> 00:05:07.662 in a timely manner. 00:05:07.662 --> 00:05:17.466 If you missed something, this topic 00:05:17.466 --> 00:05:21.454 and previous topics have been covered and have been recorded, 00:05:21.454 --> 00:05:25.897 and are or will be available on our website. 00:05:25.897 --> 00:05:28.661 If you need a minute or so to take down this website, this is the website 00:05:28.661 --> 00:05:31.737 where the webinars are located. I will 00:05:31.737 --> 00:05:33.493 give you a few seconds to take a picture, 00:05:33.493 --> 00:05:39.330 or write it down. Thank you. 00:05:39.330 --> 00:05:46.712 Great. I call this my rulings 00:05:46.712 --> 00:05:49.299 checklist, it can be used for other NIS 00:05:49.299 --> 00:05:53.592 as well, but these are the things that 00:05:53.592 --> 00:05:57.528 are required when you submit for a 00:05:57.528 --> 00:06:04.770 binding ruling for 6106 garments. Having 00:06:04.770 --> 00:06:10.785 this information helps me give you the quickest and most accurate answer. 00:06:10.785 --> 00:06:15.094 Keep in mind, the more information you provide upfront, the less likely I will have to email, 00:06:15.094 --> 00:06:15.095 or worse yet, reject for additional information. 00:06:15.095 --> 00:06:26.446 We always require our samples to be 00:06:26.446 --> 00:06:28.725 in a size adult medium. Yes, there are occasions where we receive samples that aren't, but this is our preference. 00:06:28.725 --> 00:06:30.427 We ask you try hard to get us an adult 00:06:30.427 --> 00:06:37.988 medium. 00:06:37.988 --> 00:06:44.899 We ask that the overall fiber content of the government by weight is listed in the ruling, and that is your 50-50 00:06:44.899 --> 00:06:47.350 cotton, poly, 100 percent cotton in the ruling itself. In the construction of the garment, 00:06:47.350 --> 00:06:51.999 is it Nick, woman, Jersey. 00:06:51.999 --> 00:06:59.404 We also ask for stitch count, this is something new since 00:06:59.404 --> 00:07:01.983 the new note was implemented. We are asking for a stitch count as well, though we double check and count the stitches here as well. 00:07:01.983 --> 00:07:04.543 Any marketing materials that might help 00:07:04.543 --> 00:07:08.677 classify your goods on goods that might 00:07:08.677 --> 00:07:10.587 be a little controversial. 00:07:10.587 --> 00:07:20.705 Let's get into the changes for 00:07:20.705 --> 00:07:28.630 2020, actually the changes went to 00:07:28.630 --> 00:07:31.059 effect in 2022, I call this part two. I did this webinar last year as well but there definitely are some changes that have taken place, 00:07:31.059 --> 00:07:33.491 and good information that needs to be 00:07:33.491 --> 00:07:39.180 put out to the field. 00:07:39.180 --> 00:07:39.182 I still call them the changes for 2022. 00:07:39.182 --> 00:07:49.801 Under the new 2022 note Chapter 00:07:49.801 --> 00:07:52.553 4061, the garments that are not covered remains the same as they always were in the previous years. 00:07:52.553 --> 00:08:02.371 However, it now includes new language. 00:08:02.371 --> 00:08:05.784 The new language would be in red, and that is shirts, and shirt blouses 00:08:05.784 --> 00:08:06.850 are garments designed to cover the upper part of the body having 00:08:06.850 --> 00:08:10.887 longer short sleeves and a full or 00:08:10.887 --> 00:08:11.485 partial opening starting at the neckline. 00:08:11.485 --> 00:08:11.486 00:08:11.486 --> 00:08:16.113 A full or partial opening starting 00:08:16.113 --> 00:08:16.810 at the neckline, new. 00:08:16.810 --> 00:08:22.625 Blouses are the loosefitting 00:08:22.625 --> 00:08:24.734 garments designed to cover the upper 00:08:24.734 --> 00:08:31.407 body, upper part of the body as well, 00:08:31.407 --> 00:08:33.317 but they may be sleepless or have sleeves, 00:08:33.317 --> 00:08:38.296 and may have an opening or not an 00:08:38.296 --> 00:08:38.297 opening starting at the neckline. 00:08:38.297 --> 00:08:45.347 Shirts, shirt blouses and blouses, 00:08:45.347 --> 00:08:46.877 all three may have a color. 00:08:46.877 --> 00:09:01.001 As a reminder, the harmonized task 00:09:01.001 --> 00:09:02.707 to the United States controls over thing. It is our statute and is legally binding. At the end of the day if there's any other guidelines out there that are 00:09:02.707 --> 00:09:06.700 not in line with what is presented here, 00:09:06.700 --> 00:09:09.980 or have not been updated, the harmonized 00:09:09.980 --> 00:09:12.381 schedule stands and it is our law. 00:09:12.381 --> 00:09:22.195 Characteristics of shirts and shirt 00:09:22.195 --> 00:09:26.501 blouses, I have to say I have never 00:09:26.501 --> 00:09:29.059 classified a shirt blouses, but that is 00:09:29.059 --> 00:09:34.416 always yet. They're not designed to 00:09:34.416 --> 00:09:39.416 cover the upper part of the body, having long and short sleeves, 00:09:39.416 --> 00:09:42.321 they must have a full or partial opening starting at the neckline. 00:09:42.321 --> 00:09:43.536 They may have a color treatment of any type 00:09:43.536 --> 00:09:52.812 that can be a hood, or no color at all. 00:09:52.812 --> 00:09:55.572 They must have an average of ten or more stitches per centimeter, in each direction. 00:09:55.572 --> 00:09:59.332 Measuring at least ten by ten. 00:09:59.332 --> 00:10:08.119 The pink garment with the longsleeve 00:10:08.119 --> 00:10:12.746 is, I will call it rare because I've never seen it to classify it. 00:10:12.746 --> 00:10:14.825 This particular note does not say specifically 00:10:14.825 --> 00:10:17.918 that a shirt or short blouse has to be 00:10:17.918 --> 00:10:21.521 tightfitting. However, the textile 00:10:21.521 --> 00:10:24.486 guidelines dimension that the 00:10:24.486 --> 00:10:29.125 construction may be tailored. One of the 00:10:29.125 --> 00:10:34.650 characteristics of a shirt and short 00:10:34.650 --> 00:10:38.586 blouse is, it is more tailored than a blouse would be. 00:10:38.586 --> 00:10:38.587 00:10:38.587 --> 00:10:45.810 Characteristics of the blouses, 00:10:45.810 --> 00:10:49.487 first and foremost, loosefitting. They 00:10:49.487 --> 00:10:51.859 are also designed to cover the upper part of the body. 00:10:51.859 --> 00:10:55.454 Sleeves or sleeveless, and with or 00:10:55.454 --> 00:10:57.524 without an opening starting at the neckline. 00:10:57.524 --> 00:11:02.502 That is one of the changes. They may 00:11:02.502 --> 00:11:05.957 also have a color treatment and an average of ten or more stitches. 00:11:05.957 --> 00:11:08.865 In both directions measuring ten by 00:11:08.865 --> 00:11:08.866 ten. 00:11:08.866 --> 00:11:18.391 Pockets below the waist with a 00:11:18.391 --> 00:11:20.974 ripped waistband and other means of tightening at the bottom of the garment are excluded. 00:11:20.974 --> 00:11:24.390 As well as anything, any garment having 00:11:24.390 --> 00:11:26.287 an average of less than ten stitches per 00:11:26.287 --> 00:11:26.288 centimeter. 00:11:26.288 --> 00:11:41.781 Here are some definitions that can 00:11:41.781 --> 00:11:44.698 be helpful to you, not only in 6106 but other garments as well. 00:11:44.698 --> 00:11:49.568 Neckline, people get confused with 00:11:49.568 --> 00:11:57.618 opening at the neckline. The neckline is 00:11:57.618 --> 00:12:01.082 actually the shape or contour of a garment at the shoulders, neck, or above the bust and can be high or low. 00:12:01.082 --> 00:12:05.042 You can have a deep V neckline, round 00:12:05.042 --> 00:12:09.318 neckline, crew neckline. The opening, 00:12:09.318 --> 00:12:11.566 the opening is the breach or the gap in the neckline 00:12:11.566 --> 00:12:14.989 with a functional closure, or overlap to 00:12:14.989 --> 00:12:20.665 close the gap or breach. If it is a 00:12:20.665 --> 00:12:24.986 fellow closure, that is not considered an opening. 00:12:24.986 --> 00:12:27.349 Then we have closures, which are functional trends 00:12:27.349 --> 00:12:33.547 used to open or close a garment. 00:12:33.547 --> 00:12:33.549 Some examples are snaps, zippers, buttons, ties, hooks etc. 00:12:33.549 --> 00:12:47.169 Okay, just a little backdrop. Once 00:12:47.169 --> 00:12:50.223 the new note went into effect, of course there were questions, 00:12:50.223 --> 00:12:53.157 and along with a lot of the questions 00:12:53.157 --> 00:12:57.460 were rulings. So we were getting 00:12:57.460 --> 00:12:59.157 inundated with rulings not knowing specifically 00:12:59.157 --> 00:13:01.228 how to classify when it came to 00:13:01.228 --> 00:13:04.675 loosefitting. Of course, amongst 00:13:04.675 --> 00:13:06.728 ourselves, we sought help with 00:13:06.728 --> 00:13:11.875 headquarters. I submitted to binding 00:13:11.875 --> 00:13:14.121 rulings to headquarters and asked that they guide 00:13:14.121 --> 00:13:16.880 us in reference to specifically 00:13:16.880 --> 00:13:18.760 loosefitting, and what that meant. So 00:13:18.760 --> 00:13:23.432 here are the two headquarters memos that 00:13:23.432 --> 00:13:26.360 relate to that. The garments on the memos are different, 00:13:26.360 --> 00:13:30.334 however the body and the information is the same. 00:13:30.334 --> 00:13:30.335 00:13:30.335 --> 00:13:38.722 I have taken out, extracted some of 00:13:38.722 --> 00:13:45.478 the important information I feel you might want to key in on and pull up the headquarters rulings on your own. 00:13:45.478 --> 00:13:45.479 00:13:45.479 --> 00:13:48.406 These are the ruling numbers and at 00:13:48.406 --> 00:13:50.126 your convenience, you can pull them up 00:13:50.126 --> 00:13:52.326 in cross. 00:13:52.326 --> 00:13:55.269 First, we have the issue and that 00:13:55.269 --> 00:13:57.870 is whether the women's knit upper body 00:13:57.870 --> 00:14:02.676 garments or blouses of having 6106. That 00:14:02.676 --> 00:14:09.232 is our first issue. What happens next 00:14:09.232 --> 00:14:14.543 is, we go to the EN, those are the explanatory notes, as we know. 00:14:14.543 --> 00:14:18.673 They constitute the official interpretation of the harmonized system, and that is at the international level. 00:14:18.673 --> 00:14:21.932 Even though they are not legally binding, they do provide commentary 00:14:21.932 --> 00:14:27.922 under the scope of each heading. 00:14:27.922 --> 00:14:33.426 The rulings went on to explain the 00:14:33.426 --> 00:14:35.317 definitions of shirts, shirt blouses, and blouses. 00:14:35.317 --> 00:14:40.145 However, when it defined blouses, we 00:14:40.145 --> 00:14:44.137 still had to determine whether the garment was loosefitting. 00:14:44.137 --> 00:14:45.666 This term is not defined in the legal notes, 00:14:45.666 --> 00:14:57.346 the EN or in any previously issued CBP 00:14:57.346 --> 00:14:59.634 rulings. The ruling further explained that when a tariff term is not defined, in either the tariff 00:14:59.634 --> 00:15:02.544 or its legislative history, by its 00:15:02.544 --> 00:15:09.061 correct or common meaning, a court may 00:15:09.061 --> 00:15:13.054 consult and they consult with dictionary, scientific authorities and other reliable information to 00:15:13.054 --> 00:15:13.055 try to come up with a definitive answer. 00:15:13.055 --> 00:15:19.727 In this case, that is exactly what 00:15:19.727 --> 00:15:21.094 they did, they went into consulting the Oxford English dictionary that defines 00:15:21.094 --> 00:15:26.448 loose in the context of clothes as not 00:15:26.448 --> 00:15:31.477 clinging close to the figure for loosely 00:15:31.477 --> 00:15:38.359 fitting. That is where we came up with 00:15:38.359 --> 00:15:40.613 our definitive answer. When it came to 00:15:40.613 --> 00:15:40.614 loosefitting. 00:15:40.614 --> 00:15:53.332 After we had the definition, CBP 00:15:53.332 --> 00:15:55.705 research headquarters ruling 951-9100 to determine whether the garment was loosefitting 00:15:55.705 --> 00:16:00.021 by draping both samples onto a size ten 00:16:00.021 --> 00:16:03.298 media manikin. Upon receiving the 00:16:03.298 --> 00:16:05.542 photographs and samples of the garment 00:16:05.542 --> 00:16:09.187 on the manikin, we determined that the 00:16:09.187 --> 00:16:16.236 garment did not cling to the manikin, 00:16:16.236 --> 00:16:18.444 accordingly, we determined the upper body garment is loosefitting and meets the criteria required 00:16:18.444 --> 00:16:28.637 for the term blouses in note four to 00:16:28.637 --> 00:16:31.367 Chapter 61. They also went on to mention that we cannot rely just on photos or garments worn by different body types. 00:16:31.367 --> 00:16:34.801 Instead, what CBP did, is rely solely on 00:16:34.801 --> 00:16:37.707 the manikin, and they measure certain 00:16:37.707 --> 00:16:40.502 elements of the garment that were 00:16:40.502 --> 00:16:41.352 influencing the classification. 00:16:41.352 --> 00:17:02.366 Okay, I came up with this, I call 00:17:02.366 --> 00:17:13.878 it a quick guide to classification steps for garments and heading 6106. 00:17:13.878 --> 00:17:19.890 I don't know if it is necessarily a quick guide, but hopefully it is helpful to you and when you receive a garment and don't know where to start or which way to go. 00:17:19.890 --> 00:17:19.891 00:17:19.891 --> 00:17:22.428 These are the initial steps, blouses and blouses. 00:17:22.428 --> 00:17:25.052 The first thing is, let's rule out what 00:17:25.052 --> 00:17:31.776 doesn't qualify. If you get a garment 00:17:31.776 --> 00:17:37.244 and it has pockets below the waist, right away that is not 6106, it is possibly a jacket 00:17:37.244 --> 00:17:38.976 in 6104 or cardigan in 6106, but definitely not 61– 00:17:38.976 --> 00:17:53.254 I mean a cardigan is 6110 but definitely 00:17:53.254 --> 00:17:56.354 not 6106, so there's no need to start counting stitches to figure out where it goes, it doesn't qualify. The same is if it has a waistband or other means of tightening at the bottom of the garment, 00:17:56.354 --> 00:18:00.474 clearly not 6106, more than likely 6110, 00:18:00.474 --> 00:18:04.806 but again, no need to count stitches. 00:18:04.806 --> 00:18:07.024 The next thing you must do is count 00:18:07.024 --> 00:18:10.447 the stitches of the garment. If you have 00:18:10.447 --> 00:18:15.453 less than ten stitches, this cannot be a 00:18:15.453 --> 00:18:18.039 shirt, surplus, or heading 6106. You can 00:18:18.039 --> 00:18:19.915 start right there and it is possibly 00:18:19.915 --> 00:18:24.039 garment 6109, T-shirts maybe. Similar 00:18:24.039 --> 00:18:29.870 garments or 6110. 00:18:29.870 --> 00:18:37.482 Finally, if you have ten or more stitches per centimeter, 00:18:37.482 --> 00:18:45.221 here we go, it qualifies as a garment in heading 6106 and can either be a shirt, shirt blouse, or a blouse. 00:18:45.221 --> 00:18:47.467 So these examples, as I go through, we are going to for all intensive purposes, say that every 00:18:47.467 --> 00:18:50.034 stitch count meets the requirement of a blouse, 00:18:50.034 --> 00:18:56.547 shirt blouse, and shirt. If you have a 00:18:56.547 --> 00:19:00.523 garment that has no openings starting at the neckline, 00:19:00.523 --> 00:19:09.301 right away it is a blouse. 00:19:09.301 --> 00:19:12.755 Clearly, in the tariff there is no breakout for shirt/shirt blouses specifically or blouses, but for our purposes, 00:19:12.755 --> 00:19:15.704 in coming up with the proper classification 00:19:15.704 --> 00:19:18.739 to separate it from a blouse from a shirt, 00:19:18.739 --> 00:19:21.699 a blouse would have no openings starting 00:19:21.699 --> 00:19:28.404 at the neckline. Where shirts would. If 00:19:28.404 --> 00:19:33.377 it is sleepless, it's going to be blouse only. 00:19:33.377 --> 00:19:34.953 It clearly states in the note, it can be with or without slaves. 00:19:34.953 --> 00:19:34.954 00:19:34.954 --> 00:19:38.562 If it is loosefitting, it is blouse 00:19:38.562 --> 00:19:43.545 only and if you have an opening starting 00:19:43.545 --> 00:19:49.561 at the neckline, it can be either or. So 00:19:49.561 --> 00:19:56.085 then we have to look at other features. 00:19:56.085 --> 00:19:58.337 If the stitch count meets and it's sort slaves, the garment can be 00:19:58.337 --> 00:19:59.334 either a shirt or a blouse. 00:19:59.334 --> 00:20:05.372 This is the beginning, once you 00:20:05.372 --> 00:20:11.588 have these steps you can go further and once you 00:20:11.588 --> 00:20:14.169 put them on the form if you decide if it is loosefitting or formfitting or tailored, then go further. 00:20:14.169 --> 00:20:14.170 00:20:14.170 --> 00:20:26.707 I have, going forward now, sample 00:20:26.707 --> 00:20:30.502 review slides. These are samples I have either received for a ruling, 00:20:30.502 --> 00:20:33.894 a Quick's, any other information that was needed from the field 00:20:33.894 --> 00:20:38.386 and per last year webinar, which we 00:20:38.386 --> 00:20:40.643 didn't have a lot of samples to go by, 00:20:40.643 --> 00:20:42.343 that was one of the requests during the 00:20:42.343 --> 00:20:48.876 year that the field wanted to see 00:20:48.876 --> 00:20:52.504 garments, and they wanted to see what loosefitting look like. 00:20:52.504 --> 00:20:52.505 00:20:52.505 --> 00:20:56.454 Going forward now, these are going 00:20:56.454 --> 00:20:58.846 to be samples I have reviewed already 00:20:58.846 --> 00:21:03.989 that we deemed to be loosefitting. To 00:21:03.989 --> 00:21:03.990 give you an idea, physically. 00:21:03.990 --> 00:21:09.845 This particular one, for all 00:21:09.845 --> 00:21:19.312 intensive purposes they all meet the 00:21:19.312 --> 00:21:28.751 stitch count of 6106, so there is no need to dispute that portion. They will all meet the stitch 00:21:28.751 --> 00:21:31.682 Count 46106. This one came in as 100 percent cotton, and of course, it was an early sample and they wanted 6110. 00:21:31.682 --> 00:21:34.965 We put this on the form, and based on 00:21:34.965 --> 00:21:39.745 the headquarters ruling, we felt the 00:21:39.745 --> 00:21:42.670 front clearly was not clinging to the manikin. 00:21:42.670 --> 00:21:48.375 The side view is not clinging to the 00:21:48.375 --> 00:21:48.376 manikin and on this one, the back view was not clinging to the manikin. 00:21:48.376 --> 00:21:57.148 So this ended up being a blouse, 00:21:57.148 --> 00:21:57.149 which all of these are. 00:21:57.149 --> 00:22:01.459 This is another one of our first 00:22:01.459 --> 00:22:08.819 reviews and this one came in as well 00:22:08.819 --> 00:22:13.802 wanting 6110. We put it on the manikin, 00:22:13.802 --> 00:22:18.813 and though it has, I guess you can't see 00:22:18.813 --> 00:22:21.529 it very well, it has a curved ham bottom 00:22:21.529 --> 00:22:25.829 but this clearly, as we discussed it, 00:22:25.829 --> 00:22:27.737 had no question about whether it was 00:22:27.737 --> 00:22:38.753 loosefitting. The side, you can't really 00:22:38.753 --> 00:22:42.045 see that well but clearly in the back in the front, they're not clinging to the manikin, so this 00:22:42.045 --> 00:22:42.046 was again considered a blouse. 00:22:42.046 --> 00:22:50.451 This one was described as 00:22:50.451 --> 00:22:54.434 loosefitting, and the discussions that 00:22:54.434 --> 00:22:59.406 we tend to have, the NIS is having, also 00:22:59.406 --> 00:23:04.755 the Associates have, we put these on the 00:23:04.755 --> 00:23:13.003 manikin, is it just a little more tightfitting in the back? 00:23:13.003 --> 00:23:21.447 Or is it tightfitting in the front, but not in the back, or is it just tightfitting on the side maybe to the manikin and the bottom is not. 00:23:21.447 --> 00:23:21.448 00:23:21.448 --> 00:23:27.099 In any area that is loosefitting, in other words, 00:23:27.099 --> 00:23:29.503 this is not the best example, I might have some further. 00:23:29.503 --> 00:23:34.155 But this one is a little bit more 00:23:34.155 --> 00:23:36.372 close-fitting to the manikin, but still not tightfitting 00:23:36.372 --> 00:23:41.763 and still considered loose. Along the 00:23:41.763 --> 00:23:52.538 side, and clearly in the back it is not clinging to the manikin. 00:23:52.538 --> 00:23:52.539 00:23:52.539 --> 00:24:17.377 This was a V neckline and this had 00:24:17.377 --> 00:24:17.378 a caller. So this was a wing collar, no problem there. It still qualifies, shorthand sleep and had side slits. That was helpful because using the side slits is not going to be tightfitting. 00:24:17.378 --> 00:24:21.063 Just remember that the blouses can be with or without an opening, so the back looked a little 00:24:21.063 --> 00:24:22.165 different but as we looked at it closer, no way this 00:24:22.165 --> 00:24:26.097 was going to be a shirt. This was also 00:24:26.097 --> 00:24:29.506 considered a blouse in 6106 as 00:24:29.506 --> 00:24:38.635 loosefitting. 00:24:38.635 --> 00:24:41.866 This is a sleeveless loosefitting 00:24:41.866 --> 00:24:45.836 garment that extends clearly from the 00:24:45.836 --> 00:24:51.335 shoulders to below the waist, it had a 00:24:51.335 --> 00:24:58.935 standup collar and a partial front opening with a zipper closure. 00:24:58.935 --> 00:25:01.636 There were capping at the armholes and it had a curved ham bottom with a slightly longer back panel. 00:25:01.636 --> 00:25:06.132 Now in the front view, that is pretty 00:25:06.132 --> 00:25:09.097 clear that it is not clinging to the manikin. 00:25:09.097 --> 00:25:15.788 The side view not clinging either, the back is 00:25:15.788 --> 00:25:19.611 a little, not clinging but it's there. This was still considered a loosefitting garment. 00:25:19.611 --> 00:25:19.612 00:25:19.612 --> 00:25:23.707 If the discussion, it was not even 00:25:23.707 --> 00:25:27.160 a question. Loosefitting. 00:25:27.160 --> 00:25:43.022 This one came in and they had a 00:25:43.022 --> 00:25:46.097 question in reference to the rib cuffs, 00:25:46.097 --> 00:25:54.905 that wouldn't fare well at all. We still 00:25:54.905 --> 00:25:56.625 consider this a loosefitting garment that extended clearly from the shoulders to below the waist. 00:25:56.625 --> 00:26:01.963 It featured a rib knit neckline and a 00:26:01.963 --> 00:26:09.327 chest patch pocket. A straight bottom, 00:26:09.327 --> 00:26:15.695 and had knit cuffs. Also considered a 00:26:15.695 --> 00:26:15.696 blouse, 6106 loosefitting. 00:26:15.696 --> 00:26:27.394 This one, by sight, we thought 00:26:27.394 --> 00:26:30.829 would not in the front, come all the way 00:26:30.829 --> 00:26:40.157 around past the midsection. However, it 00:26:40.157 --> 00:26:45.856 did. So extended from the shoulders and went to below the waist. 00:26:45.856 --> 00:26:57.904 It featured a crew neckline, this one had a back yoke and a curved hem 00:26:57.904 --> 00:27:01.993 back panel. With a slightly longer back panel and curved. This was also a loosefitting blouse in 6106. 00:27:01.993 --> 00:27:01.994 00:27:01.994 --> 00:27:09.258 As you can see, though this seems to be subjective, 00:27:09.258 --> 00:27:14.030 I guess when you have something that is definitively loosefitting, it is a lot more clear, it's the ones 00:27:14.030 --> 00:27:14.031 that are a little borderline or have other questions that go along with it. 00:27:14.031 --> 00:27:18.171 This one came in and they said 00:27:18.171 --> 00:27:23.516 okay, this is a sweatshirt, it is not a 00:27:23.516 --> 00:27:28.138 blouse, and it is jersey knit, and because of the weight, it 00:27:28.138 --> 00:27:33.494 was 270 grams per square meter comments the other thing I wanted to reiterate that 00:27:33.494 --> 00:27:35.883 in blouses, short blouses, and insurance, we have 00:27:35.883 --> 00:27:41.079 no requirement for weight of the fabric. 00:27:41.079 --> 00:27:44.511 As we might have in a T-shirt. So the 00:27:44.511 --> 00:27:48.960 weight of the fabric has no bearing, 00:27:48.960 --> 00:27:51.732 does this look like a blouse, probably not but after we put it on the form, 00:27:51.732 --> 00:27:55.508 and it met the requirements, for a 00:27:55.508 --> 00:28:02.931 blouse, the stitch count was there. It 00:28:02.931 --> 00:28:08.767 extended clearly from the shoulders to below the waist. There was nothing that had long sleeves, it had 00:28:08.767 --> 00:28:10.658 cuffs and it's clearly loosefitting, it does not clinging to the manikin, this was also considered a blouse. 00:28:10.658 --> 00:28:16.523 It's 106. 00:28:16.523 --> 00:28:25.290 Questions, I'm trying to break up the questions 00:28:25.290 --> 00:28:29.437 to what I have already covered so that there is not so many all at once. If there are questions in reference to any of the slides that covered already, I can address that. 00:28:29.437 --> 00:28:29.438 00:28:29.438 --> 00:28:35.949 >>CHRISSI: You have a few questions. 00:28:35.949 --> 00:28:38.197 The first one is, sleeveless. Is this over three inches excluded from the tanker must it 00:28:38.197 --> 00:28:41.965 out to the anatomical shoulder? 00:28:41.965 --> 00:28:45.898 >>ANTOINETTE: We haven't gotten to 00:28:45.898 --> 00:28:48.486 the tanks, let me, I know the one you 00:28:48.486 --> 00:28:56.611 are talking about. 00:28:56.611 --> 00:28:56.613 >>CHRISSI: Slide ten is when this came in. 00:28:56.613 --> 00:28:56.616 >>ANTOINETTE: Slide ten? 00:28:56.616 --> 00:28:59.514 >>CHRISSI: That's when it came in. 00:28:59.514 --> 00:29:02.070 >>ANTOINETTE: I think they might be talking about this 00:29:02.070 --> 00:29:06.742 one, and it is sleeveless. We have, as 00:29:06.742 --> 00:29:09.470 far as a blouse is concerned, the 00:29:09.470 --> 00:29:17.570 coverage issue here is good. It wouldn't 00:29:17.570 --> 00:29:20.309 show the brawl line and it's not even going to get to a 6109 where you have a tank top, 00:29:20.309 --> 00:29:22.402 then have to discuss coverage. I am not 00:29:22.402 --> 00:29:32.717 sure if that answers the question. 00:29:32.717 --> 00:29:36.156 >>CHRISSI: It came in on slide ten so it's a theoretical question about sleeveless. 00:29:36.156 --> 00:29:39.938 I think it's things that are considered sleeveless, 00:29:39.938 --> 00:29:43.025 three inches excluded over ten or the anatomical shoulder. 00:29:43.025 --> 00:29:43.026 00:29:43.026 --> 00:29:50.934 >>ANTOINETTE: No, it is just sleeveless 00:29:50.934 --> 00:29:52.506 requirement. Now, if it is sleeveless and it comes 00:29:52.506 --> 00:30:02.478 way below the bra line, at that point I 00:30:02.478 --> 00:30:04.702 don't know that would be covering the 00:30:04.702 --> 00:30:13.146 full upper part of the body. You're 00:30:13.146 --> 00:30:16.923 talking about the really big armholes in the tank tops that you just put something on underneath. 00:30:16.923 --> 00:30:20.718 To be honest, I would need to see that sample. 00:30:20.718 --> 00:30:22.439 To put it on a manikin to see how it falls. 00:30:22.439 --> 00:30:27.091 By question alone, that would be 6106 00:30:27.091 --> 00:30:28.639 unless it is oversized to where you 00:30:28.639 --> 00:30:32.580 could see the bra line and it has a 00:30:32.580 --> 00:30:41.766 coverage issue at that point. 00:30:41.766 --> 00:30:54.478 >>CHRISSI: Next question is do garments 00:30:54.478 --> 00:30:54.479 in 6106 have to have a closure if it's a full frontal opening? 00:30:54.479 --> 00:30:54.481 >>ANTOINETTE: No, does not have to have a closure. 00:30:54.481 --> 00:30:58.413 >>CHRISSI: Next question, do you 00:30:58.413 --> 00:31:02.203 have an actual measurement to determine 00:31:02.203 --> 00:31:06.171 loosefitting on size medium in women's? 00:31:06.171 --> 00:31:06.172 00:31:06.172 --> 00:31:07.867 >>ANTOINETTE: We don't have an actual measurement 00:31:07.867 --> 00:31:13.383 as previously stated. This was something 00:31:13.383 --> 00:31:15.973 that is new territory for everyone. There is no measurements 00:31:15.973 --> 00:31:18.373 given, however the manikin size should 00:31:18.373 --> 00:31:22.524 be a size ten medium. Based on that, and 00:31:22.524 --> 00:31:25.420 if the garment actually clings to the 00:31:25.420 --> 00:31:27.837 manikin is how we determine that we have 00:31:27.837 --> 00:31:30.408 not come up with a size of each garment 00:31:30.408 --> 00:31:35.409 saying if it is 34 inches across. That 00:31:35.409 --> 00:31:39.039 is not a medium so that is not going to 00:31:39.039 --> 00:31:41.624 be a loosefitting garment. 00:31:41.624 --> 00:31:44.704 That is why we emphasize that CBP 00:31:44.704 --> 00:31:48.134 puts them on a size medium manikin and 00:31:48.134 --> 00:31:53.295 that is standard for us. 00:31:53.295 --> 00:31:56.878 >>CHRISSI: The next question, are there specific parts of the body that we look 00:31:56.878 --> 00:32:04.858 at clinging to the body. It may cling at the Breast 00:32:04.858 --> 00:32:04.859 but maybe more flowing throughout the remainder of the garment. 00:32:04.859 --> 00:32:07.038 >>ANTOINETTE: Good question, that is something we look at. I will not see it is subjective because it isn't, 00:32:07.038 --> 00:32:11.860 but if it does not cling around the bottom 00:32:11.860 --> 00:32:15.479 on the samples that we have looked at, we consider that loosefitting. 00:32:15.479 --> 00:32:19.112 We consider that loosefitting. If there 00:32:19.112 --> 00:32:20.631 is a particular slide I have already gone through 00:32:20.631 --> 00:32:25.127 that you might feel like the bust area 00:32:25.127 --> 00:32:27.519 was a little bit more clinging than any other, 00:32:27.519 --> 00:32:33.051 that is what is trying to explain is 00:32:33.051 --> 00:32:35.952 that we sit here and look at them and discuss them, like it's a little tighter at the top, 00:32:35.952 --> 00:32:41.118 the back might touch a little bit more. 00:32:41.118 --> 00:32:42.486 So if it doesn't cling, and I have one particular slide at the end 00:32:42.486 --> 00:32:52.154 that shows a not loosefitting, I will 00:32:52.154 --> 00:32:55.253 say, a not loosefitting garment. You'll be able to see the difference clearly if you wait on that slide. 00:32:55.253 --> 00:32:56.085 I'll be able to show you, it is towards the end. 00:32:56.085 --> 00:32:56.086 00:32:56.086 --> 00:33:03.520 >>CHRISSI: This one, not sure if it 00:33:03.520 --> 00:33:06.422 is a question or comment, still need six count under 110 in case it qualifies as a sweater. 00:33:06.422 --> 00:33:06.423 00:33:06.423 --> 00:33:11.797 >>ANTOINETTE: Once it doesn't meet 00:33:11.797 --> 00:33:18.533 the stitch count for a blouse, I would 00:33:18.533 --> 00:33:20.405 refer it to a 6110 to see if it met the stitch count. 00:33:20.405 --> 00:33:28.133 However, yes, that is probably what that 00:33:28.133 --> 00:33:32.097 would have to be. There is no stitch count requirement 46109. 00:33:32.097 --> 00:33:33.297 The ones that we have come across are 00:33:33.297 --> 00:33:37.949 pretty clear where the stitch count is 00:33:37.949 --> 00:33:43.969 clearly a sweater, stitch count was not 00:33:43.969 --> 00:33:47.217 a 6106 stitch count, we haven't had any 00:33:47.217 --> 00:33:56.658 that were borderline, let's say. So far. 00:33:56.658 --> 00:33:56.659 00:33:56.659 --> 00:33:59.089 >>CHRISSI: The next question, how do you determine if the government has pockets below the waist when 00:33:59.089 --> 00:34:05.976 every body type is different, some have 00:34:05.976 --> 00:34:05.977 longer torso and some short torso. 00:34:05.977 --> 00:34:12.140 >>ANTOINETTE: Because we put it on the size 00:34:12.140 --> 00:34:16.849 medium manikin, that is what I was reiterating before, we can put every 00:34:16.849 --> 00:34:19.729 body sizes different so we have to stick what is on the form. 00:34:19.729 --> 00:34:21.602 What I showed is a simple picture, but 00:34:21.602 --> 00:34:28.840 we would have to put that on the manikin 00:34:28.840 --> 00:34:32.276 and go by the waistline to see if the pockets were below. 00:34:32.276 --> 00:34:38.649 That is the only way we do it. 00:34:38.649 --> 00:34:41.908 >>CHRISSI: The next one, when will the ICP 00:34:41.908 --> 00:34:45.537 terminology be updated with this new information? 00:34:45.537 --> 00:34:45.538 00:34:45.538 --> 00:34:54.130 >>ANTOINETTE: I don't have an answer to that question, 00:34:54.130 --> 00:35:01.543 but I can get back to you if you email me. I don't have an answer to it, I really don't know. We are working on it. 00:35:01.543 --> 00:35:01.544 00:35:01.544 --> 00:35:07.724 >>CHRISSI: I believe I was told that the ICP will be issued this year but that is all the information I have on it. 00:35:07.724 --> 00:35:07.725 00:35:07.725 --> 00:35:07.727 >>ANTOINETTE: Thank you so much. 00:35:07.727 --> 00:35:11.820 >>CHRISSI: Several INS was involved with it and they are finalizing. 00:35:11.820 --> 00:35:11.821 00:35:11.821 --> 00:35:13.059 >>ANTOINETTE: Yes, so this year. Thank you, Sandra 00:35:13.059 --> 00:35:20.768 on that. 00:35:20.768 --> 00:35:23.543 >>CHRISSI: That was Deborah. The next one is, this must have been specific to one of the items you showed. This would be a pullover in the past. 00:35:23.543 --> 00:35:23.544 00:35:23.544 --> 00:35:26.463 >>ANTOINETTE: Most of these, to be 00:35:26.463 --> 00:35:28.351 honest, would have been pullovers. Once 00:35:28.351 --> 00:35:30.946 they went to know opening at the 00:35:30.946 --> 00:35:39.886 neckline, that was the shot, right there 00:35:39.886 --> 00:35:45.229 that took it as a pullover. Most of these would have been pullovers and I think that is why 00:35:45.229 --> 00:35:47.102 just for the trade purposes, they wanted to be sure 00:35:47.102 --> 00:35:53.119 so they submit garments and you will and 00:35:53.119 --> 00:35:57.278 I might say that is loosefitting right away, they want to be sure because in the past that would've been a pullover. 00:35:57.278 --> 00:36:01.028 So they said no, is it 6110 or 6106. 00:36:01.028 --> 00:36:08.253 So we need to tell them that it is loosefitting. 00:36:08.253 --> 00:36:08.254 00:36:08.254 --> 00:36:13.084 >>CHRISSI: Okay, the next one, a previous apparel webinar mentioned the updated apparel terminology document was in the 00:36:13.084 --> 00:36:15.347 approval process which can vary, fingers crossed it will be posted soon. 00:36:15.347 --> 00:36:15.348 00:36:15.348 --> 00:36:28.557 >>ANTOINETTE: Yes, agreed. 00:36:28.557 --> 00:36:32.323 >>CHRISSI: If a government did not qualify as a blouse prior to the change in 2022, do the changes made to the tariff schedule apply to garments going forward after the changes were made? 00:36:32.323 --> 00:36:32.324 00:36:32.324 --> 00:36:44.370 >>ANTOINETTE: I don't think, if I'm 00:36:44.370 --> 00:36:55.157 understanding this correctly, wanted to know if we put it back on previous rulings, and no we did not change anything. It was already ruled upon going forward. 00:36:55.157 --> 00:36:55.158 00:36:55.158 --> 00:36:58.619 >>CHRISSI: Next, what are the specs of the size medium as size is not regulated, mediums may vary from brand to brand. 00:36:58.619 --> 00:36:58.620 00:36:58.620 --> 00:37:01.041 >>ANTOINETTE: I don't know, would 00:37:01.041 --> 00:37:06.908 you like to know the manikin and company 00:37:06.908 --> 00:37:08.950 that we use on the sized manikin? Our manikin 00:37:08.950 --> 00:37:13.078 size is ten. A size ten, I have not 00:37:13.078 --> 00:37:14.615 measured each particular area of thought 00:37:14.615 --> 00:37:18.931 manikin. But it is a standard, what we 00:37:18.931 --> 00:37:25.978 call a standard sized medium. I don't 00:37:25.978 --> 00:37:30.798 think standard size mediums very on 00:37:30.798 --> 00:37:33.239 every manikin that would be out there, I could be mistaken 00:37:33.239 --> 00:37:37.706 but we had different companies and they 00:37:37.706 --> 00:37:41.642 are all pretty consistent in the standard size medium. 00:37:41.642 --> 00:37:41.643 00:37:41.643 --> 00:37:47.470 I don't have inches to tell you if 00:37:47.470 --> 00:37:49.573 it is 36 across the bust, that is a medium. 00:37:49.573 --> 00:37:49.574 00:37:49.574 --> 00:37:55.557 >>CHRISSI: The next one how are we 00:37:55.557 --> 00:37:58.486 supposed to classify when we do not have a picture of the garment on the manikin? 00:37:58.486 --> 00:37:58.487 00:37:58.487 --> 00:38:04.850 >>ANTOINETTE: How are you supposed to classify– 00:38:04.850 --> 00:38:09.176 I'm not sure, is that from the field? 00:38:09.176 --> 00:38:09.178 >>CHRISSI: It's from somebody named Kate. 00:38:09.178 --> 00:38:13.122 >>ANTOINETTE: Is that CBP? I'm 00:38:13.122 --> 00:38:18.298 assuming this is someone in trade from 00:38:18.298 --> 00:38:23.778 the field, actually. That doesn't have a form. 00:38:23.778 --> 00:38:26.538 So they can't put it on there to classify. 00:38:26.538 --> 00:38:28.245 I would say then if that is the case, 00:38:28.245 --> 00:38:34.623 send it to me. Maybe seek to get a 00:38:34.623 --> 00:38:37.881 manikin because you would need it if you are classifying 00:38:37.881 --> 00:38:46.685 garments in 6106. At this point. Once 00:38:46.685 --> 00:38:46.686 the new note came out and they went with loosefitting, there's no other way you're going to be able to determine that. 00:38:46.686 --> 00:38:55.626 00:38:55.626 --> 00:38:59.921 >>CHRISSI: The next one, T-shirts are loosefitting, why are they not 6109? Are all loosefitting T-shirt, 00:38:59.921 --> 00:39:08.014 blouses now? 00:39:08.014 --> 00:39:12.325 >>ANTOINETTE: I will not make a general statement to say that is true, however, the way 00:39:12.325 --> 00:39:15.921 that T-shirts are coming in now, how we are wearing T-shirts, 00:39:15.921 --> 00:39:17.857 boxy, loosefitting teachers are no longer 00:39:17.857 --> 00:39:24.893 streamlined and tight, I would say a 00:39:24.893 --> 00:39:36.075 T-shirt looking type garment is going to be 6106. 00:39:36.075 --> 00:39:39.007 It doesn't matter whether it's a jersey, has so many grams per square meter. If it goes in and meets the stitch count, which a lot of them do are going to be 6106. 00:39:39.007 --> 00:39:39.008 00:39:39.008 --> 00:39:44.316 I see the question about the manikin. 00:39:44.316 --> 00:39:47.632 He is a broker, I suggest you try to get a manikin. That is what I would suggest. 00:39:47.632 --> 00:39:54.136 That is the only thing I can tell you with that, 00:39:54.136 --> 00:40:02.026 with the broker that wants to know how to classify without a manikin. It's impossible. 00:40:02.026 --> 00:40:02.027 00:40:02.027 --> 00:40:04.404 I don't want to say 6109 is phasing out, but a lot of 6109 T-shirts could be 00:40:04.404 --> 00:40:12.188 falling into 6106. 00:40:12.188 --> 00:40:17.319 >>CHRISSI: The next question, what size is required when sending a ruling for a girls garment? 00:40:17.319 --> 00:40:17.320 00:40:17.320 --> 00:40:24.018 >>ANTOINETTE: I don't have the answer to that. 00:40:24.018 --> 00:40:28.882 If you send me an email, I can email it to the NIS 00:40:28.882 --> 00:40:30.587 that would have the answer to that. I don't know if they put theirs on a size medium as well, 00:40:30.587 --> 00:40:34.193 I don't want to speak and not be 100 00:40:34.193 --> 00:40:37.455 percent accurate. I can get the 00:40:37.455 --> 00:40:41.067 information to the NIS girls, because I 00:40:41.067 --> 00:40:50.366 don't handle girls. 00:40:50.366 --> 00:40:53.125 >>SANDRA: The next one says on slide 20, there are no closures but one side overlaps the other. Is that considered an opening? 00:40:53.125 --> 00:40:53.126 00:40:53.126 --> 00:40:56.709 >>ANTOINETTE: Yes, that is a reach 00:40:56.709 --> 00:41:02.059 in the neckline. We went back and forth 00:41:02.059 --> 00:41:07.900 with that as well. Are you talking about 00:41:07.900 --> 00:41:10.113 the white garment? That is a breach. It doesn't go all the way over but it is not 00:41:10.113 --> 00:41:12.034 a straight neckline without a gap in 00:41:12.034 --> 00:41:19.587 there. I think it is this one. 00:41:19.587 --> 00:41:20.786 >>SANDRA: I think it is 120. 00:41:20.786 --> 00:41:29.037 >>ANTOINETTE: Yes. 00:41:29.037 --> 00:41:36.299 >>SANDRA: Please advise, since when a shirt cannot be sleeveless? 00:41:36.299 --> 00:41:41.122 >>ANTOINETTE: Please advise when a shirt cannot be sleeveless. 00:41:41.122 --> 00:41:41.123 00:41:41.123 --> 00:41:41.125 >>SANDRA: Since when can a shirt not be sleeveless? 00:41:41.125 --> 00:41:56.596 >>ANTOINETTE: Since it stated, 00:41:56.596 --> 00:42:02.112 having longer short sleeves. So this was 00:42:02.112 --> 00:42:06.900 part of the new chapter note. Having 00:42:06.900 --> 00:42:18.945 longer short sleeves, long or short. 00:42:18.945 --> 00:42:18.947 >> The next one, does a type that require it to be skintight? 00:42:18.947 --> 00:42:21.867 >>ANTOINETTE: I have one photo at the end that I will show you. 00:42:21.867 --> 00:42:23.610 Then you can make your determination at that point. 00:42:23.610 --> 00:42:32.022 I went too far. 00:42:32.022 --> 00:42:32.024 >>SANDRA: The next one, wouldn't the sleeveless one be considered tight around the bust? 00:42:32.024 --> 00:42:33.576 >>ANTOINETTE: Yes, I would say it was a little, 00:42:33.576 --> 00:42:37.032 yeah. I don't know if I would say tight, 00:42:37.032 --> 00:42:42.515 I would say that it was not as loose at 00:42:42.515 --> 00:42:44.600 the bottom portion, but we discussed it and went 00:42:44.600 --> 00:42:50.103 back and forth deciding on how we needed 00:42:50.103 --> 00:42:56.429 to go ahead with that one and we agreed. 00:42:56.429 --> 00:43:00.921 Myself and another NIS that would have taken it if it wasn't mine that it was loosefitting. 00:43:00.921 --> 00:43:04.001 The requester had no issue with it being loosefitting, 00:43:04.001 --> 00:43:09.152 so that is how we went. Even though we 00:43:09.152 --> 00:43:16.236 have the definition from headquarters right now as to what loosefitting is, 00:43:16.236 --> 00:43:24.955 there is still, you still have to go over it, it is still subjective to a certain degree. 00:43:24.955 --> 00:43:28.086 I'm just going to say that, it's nothing that is definitive because you are looking at it one way saying no, it is not clinging, it is clinging. 00:43:28.086 --> 00:43:31.326 So we have this definition for clarity, 00:43:31.326 --> 00:43:39.211 and we do the best we can with it. We 00:43:39.211 --> 00:43:49.555 discuss it amongst ourselves, then come up with something. If something is totally, we are one way or the other, we sent it to headquarters. 00:43:49.555 --> 00:43:49.556 00:43:49.556 --> 00:43:51.614 >>SANDRA: The next one, you mentioned a shirt with no opening at the neckline, please confirm it would fall under 00:43:51.614 --> 00:43:51.615 Category 6106? 00:43:51.615 --> 00:43:57.817 >>ANTOINETTE: Yes. Confirmed. 00:43:57.817 --> 00:44:02.325 >>SANDRA: Next, would you please elaborate on the following definition of opening, 00:44:02.325 --> 00:44:07.966 overlap to close the gap or breach. Are there any examples? 00:44:07.966 --> 00:44:07.967 00:44:07.967 --> 00:44:09.384 >>ANTOINETTE: I'm sure I have some 00:44:09.384 --> 00:44:13.675 pictures of that. Not since we have been 00:44:13.675 --> 00:44:18.479 doing the new chapter note, but I do. If 00:44:18.479 --> 00:44:20.746 you email me, I'm sure I can find some 00:44:20.746 --> 00:44:24.833 pictures of previous samples that I have 00:44:24.833 --> 00:44:32.268 reviewed that will show you that. 00:44:32.268 --> 00:44:35.507 >>SANDRA: Can blouses have sporty looks? 00:44:35.507 --> 00:44:35.508 00:44:35.508 --> 00:44:37.419 >>ANTOINETTE: I'm not sure what that means. 00:44:37.419 --> 00:44:41.194 Sport look. I would have to see that in 00:44:41.194 --> 00:44:47.542 a binding ruling. This, these are just 00:44:47.542 --> 00:44:50.461 breaking questions right now. I'm 00:44:50.461 --> 00:44:55.790 laughing because I'm like I'm not going to get any questions but 00:44:55.790 --> 00:44:58.026 this is breaking questions. I have a few more slides that I want to go through and then 00:44:58.026 --> 00:44:59.579 I can field your questions. The rest 00:44:59.579 --> 00:45:01.315 that we have. 00:45:01.315 --> 00:45:04.917 >>SANDRA: Sounds good, we will stop 00:45:04.917 --> 00:45:08.881 the questions and pick up later. Perfect. 00:45:08.881 --> 00:45:08.882 00:45:08.882 --> 00:45:12.130 >>ANTOINETTE: We can stop right here and pick back up. 00:45:12.130 --> 00:45:12.131 Thank you, I appreciate it. 00:45:12.131 --> 00:45:20.750 This is another example of a 00:45:20.750 --> 00:45:22.446 loosefitting garment that extends on the shoulders below the waist, 00:45:22.446 --> 00:45:26.117 the neckline, it has short sleeves, it 00:45:26.117 --> 00:45:29.743 has a curved hem bottom and a slightly 00:45:29.743 --> 00:45:35.413 longer back panel, and we determined 00:45:35.413 --> 00:45:36.426 this was also loosefitting. 00:45:36.426 --> 00:45:50.267 This garment has a lot of features 00:45:50.267 --> 00:45:59.511 but at the end of the day, it has cuffs 00:45:59.511 --> 00:46:03.458 and extends from the shoulder to below the waist, has a vote neckline, has extra stitching, side slits, 00:46:03.458 --> 00:46:08.634 loosefitting. 6106. This would have been 00:46:08.634 --> 00:46:13.438 a pullover, for sure. If the new note 00:46:13.438 --> 00:46:13.439 were not in play. 00:46:13.439 --> 00:46:21.031 This is another sample that had not 00:46:21.031 --> 00:46:31.189 as generic as the rest, clearly, a 00:46:31.189 --> 00:46:33.914 square neckline. It has smoking, I don't know if it is not clear, the Navy shirt and has smoking at the neckline, it is short-sleeved and has 00:46:33.914 --> 00:46:39.758 a straight hem bottom. Another 6106 at 00:46:39.758 --> 00:46:40.299 loosefitting garment. 00:46:40.299 --> 00:46:45.078 This was similar to the other one 00:46:45.078 --> 00:46:51.468 that has AB neck top to bottom shoulders 00:46:51.468 --> 00:46:53.702 to below the waist, short-sleeved, 00:46:53.702 --> 00:46:53.703 curved hem bottom. 00:46:53.703 --> 00:47:00.383 This is not snug, it is not 00:47:00.383 --> 00:47:04.327 tightfitting. It has a longer back, and 00:47:04.327 --> 00:47:09.880 we classified this as well. As 00:47:09.880 --> 00:47:12.264 loosefitting. 00:47:12.264 --> 00:47:29.785 Okay, this one extended from the 00:47:29.785 --> 00:47:33.571 shoulders to below the waist. This has a 00:47:33.571 --> 00:47:39.068 you neckline with long sleeves and a 00:47:39.068 --> 00:47:41.628 pouch pocket on the left chest, straight hem bottom, simple enough. 00:47:41.628 --> 00:47:57.664 6106, loosefitting. 00:47:57.664 --> 00:47:59.374 This one, once again, loosefitting, just a different style, 00:47:59.374 --> 00:48:04.735 it has a crewneck line, short-sleeved, a 00:48:04.735 --> 00:48:06.074 small patch pocket that you probably 00:48:06.074 --> 00:48:09.689 can't see. If you look hard, decide 00:48:09.689 --> 00:48:15.024 portion you can see is clearly not 00:48:15.024 --> 00:48:15.025 loosefitting. The back is considered loosefitting, total garment loosefitting. 00:48:15.025 --> 00:48:23.291 Let me see before we go to anymore 00:48:23.291 --> 00:48:43.546 questions. This is a longsleeved garment 00:48:43.546 --> 00:48:45.767 featuring a crewneck line, hem bottom with rattling sleeves and a straight hem bottom. 00:48:45.767 --> 00:48:48.356 This is also loosefitting. 00:48:48.356 --> 00:48:57.459 This was questionable but we put it 00:48:57.459 --> 00:48:59.047 in loosefitting. It met the requirements 00:48:59.047 --> 00:49:08.339 of stitch count extending from the 00:49:08.339 --> 00:49:15.419 shoulders to below the waist, round neckline, short sleeves, but the left side at the waist 00:49:15.419 --> 00:49:18.859 is where we were going back and forth. It has a curved bottom and straight hem bottom. 00:49:18.859 --> 00:49:22.085 Not enough tightening around the manikin 00:49:22.085 --> 00:49:22.086 to be anything but loosefitting. 00:49:22.086 --> 00:49:35.580 By size, we thought this would meet 00:49:35.580 --> 00:49:40.200 the waist all the way around but once we put it on the form, we realized it did extend from the shoulder to below the waist. 00:49:40.200 --> 00:49:44.684 It had arisen crewneck line, long sleeves, it has 00:49:44.684 --> 00:49:49.319 rib cuffs and a slightly longer back. 00:49:49.319 --> 00:49:49.320 This is also loosefitting, 6106 loose garment. 00:49:49.320 --> 00:49:57.054 This is not a loosefitting garment, 00:49:57.054 --> 00:50:00.705 so far, that I have seen since the new 00:50:00.705 --> 00:50:06.170 note went into play. This went as a 00:50:06.170 --> 00:50:09.478 6110, I believe. This is what we would 00:50:09.478 --> 00:50:14.969 consider to be not loosefitting. 00:50:14.969 --> 00:50:33.911 Compared to all the other loosefitting, even at the bust 00:50:33.911 --> 00:50:33.912 line. This is our comparison, so to speak. As far as loosefitting is concerned and what isn't. What doesn't conform or fit to the manikin. 00:50:33.912 --> 00:50:47.832 This is a recent one, and actually, 00:50:47.832 --> 00:50:51.597 we were going back and forth because of the 00:50:51.597 --> 00:50:54.040 not tightening at the waist, actually. 00:50:54.040 --> 00:50:57.650 This was a woman's blouse, and it had 00:50:57.650 --> 00:51:02.281 the cotton stitch count, even though it 00:51:02.281 --> 00:51:07.162 had the cotton stitch count of a blouse, 00:51:07.162 --> 00:51:08.879 the outer surface measured and chooses 00:51:08.879 --> 00:51:13.487 to do more. By sight, it's like a 00:51:13.487 --> 00:51:17.790 sweatshirt. That is what we classified 00:51:17.790 --> 00:51:22.259 it as, a loosefitting sweatshirt style 00:51:22.259 --> 00:51:26.221 garment that has a rib crew neckline, 00:51:26.221 --> 00:51:34.475 long sleeves, rib cuffs, and I knit 00:51:34.475 --> 00:51:34.476 bottom with side slits and a slightly longer back bottom, back panel. 00:51:34.476 --> 00:51:42.091 I don't know if this is last, but 00:51:42.091 --> 00:51:47.765 not least, one of our request as 00:51:47.765 --> 00:51:49.777 Alexandra Wayne was so kind to let me share this ruling, 00:51:49.777 --> 00:51:55.318 which was brand-new, it is what we are 00:51:55.318 --> 00:51:59.293 calling a unisex blouse at this point. 00:51:59.293 --> 00:52:03.053 The ruling came in and they wanted to know, 00:52:03.053 --> 00:52:04.770 what is this. Is this a T-shirt, a blouse, 00:52:04.770 --> 00:52:10.075 a pullover. So two different garments, 00:52:10.075 --> 00:52:13.692 garments a and B are both constructed of 00:52:13.692 --> 00:52:21.626 100 percent cotton jersey, and met the 00:52:21.626 --> 00:52:24.873 stitch Count 1 is longsleeved, one is short-sleeved, both extend from the shoulders to the waist. 00:52:24.873 --> 00:52:26.041 The rib neckline, large green print self 00:52:26.041 --> 00:52:32.135 bottom. We believe this is a very unique 00:52:32.135 --> 00:52:35.379 situation when it came to unisex. 00:52:35.379 --> 00:52:38.283 T-shirt style garments. As we are aware, 00:52:38.283 --> 00:52:40.516 unisex garments are to be classified for 00:52:40.516 --> 00:52:48.802 which women's garments are chapter 6109. 00:52:48.802 --> 00:52:48.803 00:52:48.803 --> 00:52:51.735 At the reviewing the ruling, myself, and to other NIS's 00:52:51.735 --> 00:52:54.802 got together at length to discuss what 00:52:54.802 --> 00:53:03.770 heading we were going to classify these garments in. 00:53:03.770 --> 00:53:08.595 If they were truly unisex because of the specifications of the garment, which is loosefitting, would be classified as 6106 as a blouse. 00:53:08.595 --> 00:53:13.931 A unisex blouse, meaning of course, a 00:53:13.931 --> 00:53:15.817 man could wear the garment is something we have never heard of, not yet classified. 00:53:15.817 --> 00:53:26.349 If by chance it met the measurement 00:53:26.349 --> 00:53:28.590 standards for men, it would eventually be classified as a pullover because of the weight, 240 grams per square meter. 00:53:28.590 --> 00:53:34.218 Trust me, I don't do men. Men's 00:53:34.218 --> 00:53:36.278 requirements are not something I have, I 00:53:36.278 --> 00:53:41.280 would have to confirm with any other NIS 00:53:41.280 --> 00:53:42.842 for that. However, it was for the U.S. 00:53:42.842 --> 00:53:47.991 standard chart it went by. These 00:53:47.991 --> 00:53:55.213 garments between men's size large, which 00:53:55.213 --> 00:53:59.847 the chest size was 42– 44, and size extra-large, chest size 00:53:59.847 --> 00:54:03.452 was 46– 48. Therefore, each of the submitted samples 00:54:03.452 --> 00:54:04.833 is larger than a men's standard medium. 00:54:04.833 --> 00:54:10.859 At that point, NIS, we discussed it and 00:54:10.859 --> 00:54:14.790 since the garments met the requirements of the blouse 00:54:14.790 --> 00:54:23.736 and not specifically designed for one gender over another 00:54:23.736 --> 00:54:23.737 and are constructed in sizes to accommodate both sexes, it would classify it in 6106 as a unisex blouse. 00:54:23.737 --> 00:54:27.330 That is where we went with that 00:54:27.330 --> 00:54:36.104 one. And I have, I have the ruling 00:54:36.104 --> 00:54:44.020 number. For clarification if you want 00:54:44.020 --> 00:55:04.322 it. It is N 330506. I don't know if I 00:55:04.322 --> 00:55:04.323 should type that in the chat. 00:55:04.323 --> 00:55:07.212 That concludes the webinar for today, I'm hoping the samples helped you guys get some type of better understanding. 00:55:07.212 --> 00:55:12.066 If not, I'm always here, binding rules 00:55:12.066 --> 00:55:14.658 of the West way to go for the field. 00:55:14.658 --> 00:55:19.485 Cliques are the best way to go as well. 00:55:19.485 --> 00:55:22.382 This is my contact information as well as my associates. 00:55:22.382 --> 00:55:26.541 My samples can be mailed to one World 00:55:26.541 --> 00:55:31.164 Trade Center, which is right here as well. 00:55:31.164 --> 00:55:31.165 00:55:31.165 --> 00:55:35.628 Now, any last-minute further 00:55:35.628 --> 00:55:39.244 questions that I can help with right 00:55:39.244 --> 00:55:43.861 now? I would be glad to answer. 00:55:43.861 --> 00:55:55.726 >>SANDRA: So we will continue where we left off earlier, you have quite a few questions. 00:55:55.726 --> 00:55:57.303 This one says, was the last garment on the inside, this is when we were on slide 25 so I believe it is referencing slide 24. 00:55:57.303 --> 00:55:59.714 Was the last garment napped on the 00:55:59.714 --> 00:56:04.570 inside? 00:56:04.570 --> 00:56:11.401 >>ANTOINETTE: Yes, it was. 00:56:11.401 --> 00:56:14.520 >>SANDRA: Do you have any pictures of tightfitting that moves it from 60106-2610? 00:56:14.520 --> 00:56:19.477 >>ANTOINETTE: The only tightfitting 00:56:19.477 --> 00:56:22.402 was the last garment I showed you that was the pink one. 00:56:22.402 --> 00:56:25.192 Literally, we have not come across a 00:56:25.192 --> 00:56:28.258 whole lot of tightfitting. That was this 00:56:28.258 --> 00:56:32.226 one. Clearly, it is one extreme to the 00:56:32.226 --> 00:56:37.035 other but this is the only one that for 00:56:37.035 --> 00:56:39.279 sure went into his 6110. 00:56:39.279 --> 00:56:44.243 >>SANDRA: There was another question 00:56:44.243 --> 00:56:52.336 for us to go back to slide seven, you can do that later about the ruling. 00:56:52.336 --> 00:56:53.200 The next question, can the functional opening be at the back of the garment to be considered a shirt or shirt blouse? 00:56:53.200 --> 00:56:53.201 00:56:53.201 --> 00:57:03.358 >>ANTOINETTE: Yes. 00:57:03.358 --> 00:57:03.360 >>SANDRA: Can you explain–. 00:57:03.360 --> 00:57:04.552 >>ANTOINETTE: Starting at the neckline, doesn't matter if it's in the front or the back. 00:57:04.552 --> 00:57:07.607 Before the next question, can explain 00:57:07.607 --> 00:57:09.518 what stitch count means, definition? 00:57:09.518 --> 00:57:15.218 >>ANTOINETTE: Oh, man. That is a 00:57:15.218 --> 00:57:21.895 whole another webinar and a whole another question. 00:57:21.895 --> 00:57:26.889 Can that person email me and I can give you some information on stitch count and how we count our stitches? 00:57:26.889 --> 00:57:29.642 There might even be a webinar out there but I can let you know 00:57:29.642 --> 00:57:33.458 what that is, and try to give you a quick 00:57:33.458 --> 00:57:34.816 little rundown of how to count stitches. 00:57:34.816 --> 00:57:34.817 00:57:34.817 --> 00:57:40.524 >>SANDRA: Next question, is there a 00:57:40.524 --> 00:57:48.890 coverage requirement for shoulders or back 46106 blouses? 00:57:48.890 --> 00:57:48.891 00:57:48.891 --> 00:57:53.031 >>ANTOINETTE: It just says cover the upper body garment. 00:57:53.031 --> 00:57:59.641 I haven't run into any right now, where 00:57:59.641 --> 00:58:04.011 they are way off. I will say this, if they are not covering the shoulders, 00:58:04.011 --> 00:58:07.464 something like that that is extreme, I 00:58:07.464 --> 00:58:14.715 think that it would probably not even 00:58:14.715 --> 00:58:17.477 meet the coverage requirements for 6110 and it might even go into a 6114. 00:58:17.477 --> 00:58:20.387 But right now, I don't have anything 00:58:20.387 --> 00:58:25.561 that would fit that garment. 00:58:25.561 --> 00:58:32.634 >>SANDRA: Okay, you mentioned a form 00:58:32.634 --> 00:58:34.497 of futures used to determine classification, is this form of features available to the public? 00:58:34.497 --> 00:58:34.498 00:58:34.498 --> 00:58:41.553 >>ANTOINETTE: My particular slide? 00:58:41.553 --> 00:58:44.805 I'm not sure when you what you meant by 00:58:44.805 --> 00:58:47.420 form of features. Basic features for 00:58:47.420 --> 00:58:50.754 6106? They are in one of these slides to 00:58:50.754 --> 00:58:55.666 the front. Because the basic features 00:58:55.666 --> 00:58:59.815 46106 pretty much, let me find the slide 00:58:59.815 --> 00:59:15.590 for you. I'll give you a better one. 00:59:15.590 --> 00:59:19.250 These are the characteristics, this is the blouse, and in slide ten, and this would be the shirt. 00:59:19.250 --> 00:59:22.675 In nine. 00:59:22.675 --> 00:59:31.938 They are clear in the note as well. 00:59:31.938 --> 00:59:31.939 00:59:31.939 --> 00:59:38.311 >>SANDRA: The next and says aren't most of your examples T-shirts? 00:59:38.311 --> 00:59:38.312 00:59:38.312 --> 00:59:41.565 >>ANTOINETTE: Actually, if they were 00:59:41.565 --> 00:59:43.778 not the new note, I'm not sure that they 00:59:43.778 --> 00:59:47.102 would meet the requirement for the 00:59:47.102 --> 00:59:49.500 T-shirt and less they were Jersey. They 00:59:49.500 --> 00:59:55.717 would probably be pullovers. In 6110, 00:59:55.717 --> 01:00:01.893 there might be a few of them that would fall into a T-shirt. 01:00:01.893 --> 01:00:06.365 On a T-shirt, you have to have the jersey net but they would probably be pullovers. 01:00:06.365 --> 01:00:06.366 01:00:06.366 --> 01:00:08.752 >>SANDRA: Isn't the guideline two 01:00:08.752 --> 01:00:21.139 inches for a tank strap? 01:00:21.139 --> 01:00:25.650 >>ANTOINETTE: A two-inch tank strap is specifically for tank tops. That has nothing to do with blouses. 01:00:25.650 --> 01:00:30.766 That particular one that was sleeveless 01:00:30.766 --> 01:00:34.893 didn't have a strap on it, I haven't come across one yet with a strap on it. 01:00:34.893 --> 01:00:43.710 It is correct though, it is two inches 01:00:43.710 --> 01:00:43.711 for the tank tops. 01:00:43.711 --> 01:00:57.610 >>SANDRA: What about plus size blouses? What is the medium sample size to see if it is loosefitting on the mannequin? 01:00:57.610 --> 01:00:57.611 01:00:57.611 --> 01:01:12.441 >>ANTOINETTE: We have plus size manikins, 01:01:12.441 --> 01:01:16.546 so a medium plus size mannequin, I'm not sure what size that would be to be honest with you, I haven't had a plus size but we have manikins in the office that we can put a sample on. 01:01:16.546 --> 01:01:16.547 01:01:16.547 --> 01:01:21.546 >>SANDRA: Okay. There was one that 01:01:21.546 --> 01:01:23.454 says the blue one does not cover the shoulder. 01:01:23.454 --> 01:01:23.455 01:01:23.455 --> 01:01:38.540 >>ANTOINETTE: The blue one? This 01:01:38.540 --> 01:01:45.487 one? This covers. 01:01:45.487 --> 01:01:47.027 >>SANDRA: I'm not sure. 01:01:47.027 --> 01:01:55.478 >>ANTOINETTE: This covers, it covers 01:01:55.478 --> 01:02:00.095 enough. It might not be that clear in 01:02:00.095 --> 01:02:05.308 the picture, but it definitely covers enough of the shoulder 01:02:05.308 --> 01:02:07.335 be a 6106, it has to cover the upper part of the body. 01:02:07.335 --> 01:02:11.473 From shoulder to below. It doesn't have 01:02:11.473 --> 01:02:16.439 to be from the neck down, we determined 01:02:16.439 --> 01:02:24.205 that this covered enough of the shoulder. 01:02:24.205 --> 01:02:24.206 01:02:24.206 --> 01:02:26.772 >>SANDRA: The next one, if you do not have a picture, how would you determine the stitch count? 01:02:26.772 --> 01:02:26.773 01:02:26.773 --> 01:02:31.400 >>ANTOINETTE: You need the garment 01:02:31.400 --> 01:02:37.247 to determine the stitch count, we don't use pictures. 01:02:37.247 --> 01:02:39.993 These pictures were taken from actual garments I have already seen and counted the stitches. 01:02:39.993 --> 01:02:43.921 Without a garment, and you can't do 01:02:43.921 --> 01:02:49.475 anything. In other words, when you 01:02:49.475 --> 01:02:52.046 submit your ruling to me, if this is the 01:02:52.046 --> 01:02:58.957 question and you submit your garment, 01:02:58.957 --> 01:02:59.981 and you tell me it has ten or more stitches, okay. Then I'm going to count it when I get 01:02:59.981 --> 01:03:05.008 the garment in and I'm going to put it 01:03:05.008 --> 01:03:11.392 on the floor. 01:03:11.392 --> 01:03:13.401 >>SANDRA: What if the government does not have a closure that has a full frontal opening 01:03:13.401 --> 01:03:21.169 and the government becomes a cardigan. 01:03:21.169 --> 01:03:31.656 >>ANTOINETTE: No, not necessarily. 01:03:31.656 --> 01:03:37.844 It would depend upon the stitch count because the insureds you can have a full or partial opening starting at the neckline so the stitch count is what rules that out. 01:03:37.844 --> 01:03:53.650 If it met a sweater stitch Count would 01:03:53.650 --> 01:03:57.970 no longer be a 6106. Have we come across one with a full frontal opening yet? No. But who is to say. I want to agree with you that nine times out of ten if it's a full frontal opening, you probably wouldn't 01:03:57.970 --> 01:04:03.609 see a short but we have not come across that garment yet. 01:04:03.609 --> 01:04:03.610 01:04:03.610 --> 01:04:07.908 >>SANDRA: Can blouses be for sports 01:04:07.908 --> 01:04:13.595 use? Some tops excluded from tank tops 01:04:13.595 --> 01:04:13.596 or other top something that is under 6100 report. 01:04:13.596 --> 01:04:22.352 >>ANTOINETTE: Can you repeat that? 01:04:22.352 --> 01:04:27.493 >>SANDRA: Can blouses be for sports use? Some sleeveless tops that are excluded from tank tops or other tank tops. 01:04:27.493 --> 01:04:29.414 Something that would have been under 6100 before. 01:04:29.414 --> 01:04:29.415 01:04:29.415 --> 01:04:32.845 >>ANTOINETTE: Yes, if it met the 01:04:32.845 --> 01:04:39.373 stitch count, absolutely. When you're 01:04:39.373 --> 01:04:45.042 talking about a blouse, it would have to be loosefitting. 01:04:45.042 --> 01:04:45.043 01:04:45.043 --> 01:04:49.026 >>SANDRA: What kicked the first 01:04:49.026 --> 01:04:52.099 sample into a T-shirt classification? 01:04:52.099 --> 01:04:58.678 >>ANTOINETTE: The first one? This 01:04:58.678 --> 01:05:06.578 one? 01:05:06.578 --> 01:05:09.329 >>SANDRA: I'm not sure if it was this one or after we finished the first round of questions. 01:05:09.329 --> 01:05:09.330 01:05:09.330 --> 01:05:10.161 >>ANTOINETTE: I will be honest, if it 01:05:10.161 --> 01:05:17.098 was Jersey, and I don't think it is, I 01:05:17.098 --> 01:05:23.115 think it was a net, say it was jersey 01:05:23.115 --> 01:05:25.659 net, there's nothing that would really 01:05:25.659 --> 01:05:30.356 have taken it out of 6106. And put it 01:05:30.356 --> 01:05:34.257 into a T-shirt, we are talking before 01:05:34.257 --> 01:05:43.728 the new chapter no. This was jersey knit 01:05:43.728 --> 01:05:48.184 that would have been a T-shirt all day everyday. Yes. 01:05:48.184 --> 01:05:48.185 01:05:48.185 --> 01:05:50.765 >>SANDRA: What is the difference or 01:05:50.765 --> 01:06:03.504 requirement between the samples you 01:06:03.504 --> 01:06:12.075 should pictured classified under 6106 versus 16109 versus T-shirt or article. You want me to repeat that? What is the difference or requirements 01:06:12.075 --> 01:06:12.076 between the samples you showed pictures of classifying under 6106 versus 6109 under teacher or similar articles? 01:06:12.076 --> 01:06:15.179 >>ANTOINETTE: The difference would 01:06:15.179 --> 01:06:19.476 be the stitch count. What I was 01:06:19.476 --> 01:06:27.567 expending before when he went to T-shirts, 01:06:27.567 --> 01:06:31.365 is that the thing with blouses in 6106, is it does not have a gram per square meter requirement. 01:06:31.365 --> 01:06:32.538 Because of that, nothing is going to jump to T-shirts. 01:06:32.538 --> 01:06:37.024 If it did, sir. A lot of these garments 01:06:37.024 --> 01:06:43.115 that meet the gram per square meter 01:06:43.115 --> 01:06:58.704 requirement jumped to a t-shirt in 6109 01:06:58.704 --> 01:06:58.705 but because we don't have that requirement in 6106, there is nothing to take it out of 6106, nothing at all. 01:06:58.705 --> 01:07:03.660 I'm not saying we are doing away with T-shirts, but there is nothing specific 01:07:03.660 --> 01:07:05.909 requirement in the 6106 that would bring that to a T-shirt. 01:07:05.909 --> 01:07:05.910 01:07:05.910 --> 01:07:12.405 >>SANDRA: Okay. The next one, is 01:07:12.405 --> 01:07:17.757 there a coverage requirement for shoulders or back 46106 blouses? 01:07:17.757 --> 01:07:17.758 01:07:17.758 --> 01:07:21.189 >>ANTOINETTE: Once again, it just says 01:07:21.189 --> 01:07:23.602 upper body, covered the upper part. I 01:07:23.602 --> 01:07:25.657 haven't had any that was that subjective, 01:07:25.657 --> 01:07:28.942 to be honest with you. I have not run 01:07:28.942 --> 01:07:35.632 into any that didn't cover the upper 01:07:35.632 --> 01:07:44.918 body part. And down. When we get that 01:07:44.918 --> 01:07:50.119 garment, we will put it on the form to see if we have coverage issues. 01:07:50.119 --> 01:07:53.026 That it doesn't cover, but it would have to totally almost not cover the top part. 01:07:53.026 --> 01:08:00.636 Then to be honest, if it really doesn't 01:08:00.636 --> 01:08:03.218 cover the top part 46106, it probably wouldn't cover the top part 46110 either. 01:08:03.218 --> 01:08:06.649 I think the coverage requirements for 01:08:06.649 --> 01:08:08.188 that as well. It might end up to be in the 01:08:08.188 --> 01:08:22.271 6114, that's what it would be. 01:08:22.271 --> 01:08:25.712 >>SANDRA: On the slide characteristics of blouses, it honestly sounds like any loose T-shirt can become a blouse. 01:08:25.712 --> 01:08:25.713 01:08:25.713 --> 01:08:29.505 >>ANTOINETTE: Absolutely. 01:08:29.505 --> 01:08:33.645 >>SANDRA: The next one, so in other 01:08:33.645 --> 01:08:34.837 words the majority of the garment should 01:08:34.837 --> 01:08:40.001 not be clinging in order to qualify for 01:08:40.001 --> 01:08:41.918 loose garments under 6106 size medium 01:08:41.918 --> 01:08:51.565 adult. They should not cling in order to 01:08:51.565 --> 01:08:51.566 qualify for a loose garment under 6106. 01:08:51.566 --> 01:08:54.497 >>ANTOINETTE: Yes. Like I've said 01:08:54.497 --> 01:08:56.585 before, we really haven't found any in 01:08:56.585 --> 01:09:01.173 the middle. They're usually really not 01:09:01.173 --> 01:09:06.691 clinging, or like the last one that I 01:09:06.691 --> 01:09:08.759 showed you that went to 6110, it is 01:09:08.759 --> 01:09:13.061 clinging. I haven't found any really in 01:09:13.061 --> 01:09:17.012 the middle, there's been a couple but it 01:09:17.012 --> 01:09:19.579 might cling a little at the top, but not at the bottom. 01:09:19.579 --> 01:09:22.198 It's still 6106. We haven't had any that 01:09:22.198 --> 01:09:26.991 were like really really borderline. 01:09:26.991 --> 01:09:44.719 If we did and we were undecided, I 01:09:44.719 --> 01:09:44.720 would say 6110 says no, that is mine and I would say it would just go to headquarters. 01:09:44.720 --> 01:09:49.674 >>SANDRA: This is the, this means all cotton tops will go from 16.5 percent 01:09:49.674 --> 01:09:52.794 to 17.5 percent, that is very high for costing. 01:09:52.794 --> 01:09:52.795 01:09:52.795 --> 01:09:56.734 >>ANTOINETTE: I agree, this is something we have been hearing from 01:09:56.734 --> 01:09:59.834 the trade since the new note was implemented. 01:09:59.834 --> 01:10:02.081 I hear you, I understand it. You are 01:10:02.081 --> 01:10:11.028 absolutely right. By sight, when you 01:10:11.028 --> 01:10:15.351 look at some of these garments and you say wow, 01:10:15.351 --> 01:10:19.290 does that look like a blouse or a T-shirt, but 01:10:19.290 --> 01:10:26.149 we are not here, we are here to follow the rules and the law. 01:10:26.149 --> 01:10:26.150 01:10:26.150 --> 01:10:33.368 >>SANDRA: The next comment or question, how can a blouse or shirt not have an opening at the neckline? 01:10:33.368 --> 01:10:33.369 01:10:33.369 --> 01:10:34.202 >>ANTOINETTE: Before I answer that, I'm going to stop at 2:44 p.m., 01:10:34.202 --> 01:10:39.565 right? Just because we are coming to cut 01:10:39.565 --> 01:10:45.768 off sometime. Go ahead, what was the 01:10:45.768 --> 01:10:45.769 question? 01:10:45.769 --> 01:10:50.238 >>SANDRA: How can a blouse or shirt not have an opening at the neckline? 01:10:50.238 --> 01:10:50.239 01:10:50.239 --> 01:10:53.481 >>ANTOINETTE: How can a blouse or a 01:10:53.481 --> 01:10:56.574 shirt not have an opening– I'm not 01:10:56.574 --> 01:11:02.246 getting that question. Blouses don't 01:11:02.246 --> 01:11:05.392 have openings and the shirts do? I'm not 01:11:05.392 --> 01:11:08.992 understanding the question 100 percent. 01:11:08.992 --> 01:11:08.993 01:11:08.993 --> 01:11:12.260 >>SANDRA: How could a blouse or a shirt not have 01:11:12.260 --> 01:11:15.357 an opening at the neckline. 01:11:15.357 --> 01:11:25.493 >>ANTOINETTE: Shirts and shirt 01:11:25.493 --> 01:11:28.419 blouses designed to cover the upper part of the body, for example, full or partial opening. Then when you get to blouses, they can have 01:11:28.419 --> 01:11:34.112 an opening or not an opening. So to have 01:11:34.112 --> 01:11:37.192 a shirt, you have to have an opening, to have a blouse, it's either way. 01:11:37.192 --> 01:11:39.921 You can have one or not have one. The 01:11:39.921 --> 01:11:42.194 distinction is loosefitting. That is the 01:11:42.194 --> 01:11:44.951 distinction in that part of the 01:11:44.951 --> 01:11:50.092 description. It is loosefitting. Nine 01:11:50.092 --> 01:11:52.669 times out of ten is loosefitting and going to go into a blouse. 01:11:52.669 --> 01:11:55.963 The only one I felt that was 01:11:55.963 --> 01:12:01.799 Taylor, that is why I mentioned Taylor, 01:12:01.799 --> 01:12:05.411 that was mentioned in the textile guidelines, they cited something as shirts being more tailored. 01:12:05.411 --> 01:12:14.518 That was this picture. This is just a 01:12:14.518 --> 01:12:16.078 picture, I never had the sample but I tried to bring to light something that might be more tailored that would fit into 01:12:16.078 --> 01:12:19.347 a shirt with an opening. Not into a 01:12:19.347 --> 01:12:26.735 blouse. That would be that. 01:12:26.735 --> 01:12:30.877 We have two minutes. Any other 01:12:30.877 --> 01:12:35.173 questions after the two minutes can be forwarded to me. 01:12:35.173 --> 01:12:37.428 Via my email, and I will put that back up for you. 01:12:37.428 --> 01:12:39.479 I appreciate you listening, and I 01:12:39.479 --> 01:12:41.181 appreciate all the questions. That helps 01:12:41.181 --> 01:12:51.680 me, and helps you as well. 01:12:51.680 --> 01:12:55.301 >>SANDRA: People had mentioned if you could show slide 71 more time, that was the requirements for the ruling. 01:12:55.301 --> 01:12:58.026 Let's do that, let them take a picture and then you can 01:12:58.026 --> 01:12:58.027 go. 01:12:58.027 --> 01:13:35.335 >>ANTOINETTE: No problem. Okay, we 01:13:35.335 --> 01:13:39.147 are going to end now. For those who didn't 01:13:39.147 --> 01:13:41.878 get questions answered, email me your questions. 01:13:41.878 --> 01:13:43.784 And/or call me as well. We can 01:13:43.784 --> 01:13:48.795 communicate through email, there are 01:13:48.795 --> 01:13:52.373 days that I'm in the office. If you email me, 01:13:52.373 --> 01:13:56.347 or you need to speak, we can do that as well. 01:13:56.347 --> 01:13:56.348 01:13:56.348 --> 01:14:00.452 Thank you for tuning in, I appreciate it. 01:14:00.452 --> 01:14:02.180 I don't know if Debbie wanted to say something, 01:14:02.180 --> 01:14:10.821 or if that is it? 01:14:10.821 --> 01:14:22.635 >> Thank you, just wanted to reiterate what you said already that the ICP, 01:14:22.635 --> 01:14:26.304 the terminology of the ICP, we are planning to issue it as soon as we can, it will be issued this year. We are just fine-tuning it and there's a lot of with what you said, NIS is involved in this 01:14:26.304 --> 01:14:32.477 one and with all of the tariff changes, we just want to be sure 01:14:32.477 --> 01:14:36.084 of all the different updates, make sure it is clear enough for everybody that is going to be using it as a guide. 01:14:36.084 --> 01:14:38.177 Stay tuned, it'll be coming out soon. Thank you. 01:14:38.177 --> 01:14:38.178 01:14:38.178 --> 01:14:42.792 >>ANTOINETTE: Thank you, Debbie. 01:14:42.792 --> 01:14:42.794 >> Thanks a lot, great webinar. 01:14:42.794 --> 01:14:45.025 >>ANTOINETTE: Thank you everyone. 01:14:45.025 --> 01:14:50.690 >>SANDRA: If you could go back to 01:14:50.690 --> 01:14:50.691 the last slide with your contact information. 01:14:50.691 --> 01:15:10.970 >>ANTOINETTE: Okay. 01:15:14.950 --> 01:15:14.950 Thank you for joining us and enjoy the rest of your day.