In NY N301235, Customs and Border Protection (CBP) discussed the classification of the “Mac in a Sac,” a woman’s down jacket with an accompanying bag. The item in question is a reversible hip-length jacket constructed from 100% nylon, woven fabric that is quilted to a 100% nylon, woven fabric, and filled with a mixture of down and feathers. The jacket features a full front opening with a zipper closure that extends to the top of a stand-up collar; zippered pockets below the waist on one side, and unsecured pockets on the reverse side; long sleeves with elasticized fabric, bound cuffs; and an elasticized fabric, bound bottom. The jacket comes with a cylindrical storage bag made of 100% polyester woven fabric. The bag is approximately 7 ½ inches by 6 inches when flat, and contains a draw cord closure with a cord lock on the open end.

The CBP laboratory analyzed the women’s garment and found that it contains over 10% by weight of down.

The agency has previously ruled that similar bags imported and sold with a garment constructed from the same fabric and in the same color are composite goods, with the essential character imparted by the garment. Therefore, the bags and jackets are classified together.

 

Furthermore, CBP ruled that the applicable HTSUS for this item is 6202.93.1500, which provides for: Women’s or girls’ overcoats, carcoats, capes, cloaks, anoraks (including ski-jackets), windbreakers and similar articles (including padded, sleeveless jackets), other than those of heading 6204: Anoraks (including ski-jackets), windbreakers and similar articles (including padded, sleeveless jackets): Of man-made fibers: Other: Containing 15 percent or more by weight of down and waterfowl plumage and of which down comprises 35 percent or more by weight; containing 10 percent or more by weight of down. The rate of duty will be 4.4% ad valorem.

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.