What Every Member of the 

Trade Community Should Know About: 

 Classification of Knit 

to Shape Garments 

under HTSUS 

Heading 6110 

AN INFORMED COMPLIANCE PUBLICATION 

MAY 2008 
Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

NOTICE:

This publication is intended to provide guidance and information to the trade community. 

It reflects the position on or interpretation of the applicable laws or regulations by U.S. 

Customs and Border Protection (CBP) as of the date of publication, which is shown on 

the front cover. It does not in any way replace or supersede those laws or regulations. 

Only the latest official version of the laws or regulations is authoritative. 

Publication History 

First Issued June 2006 

Reviewed with no changes May 2008 

PRINTING NOTE: 

This publication was designed for electronic distribution via the CBP website 

(http://www.cbp.gov) and is being distributed in a variety of formats. It was originally set 

up in Microsoft Word 2003®. Pagination and margins in downloaded versions may vary 

depending upon which word processor or printer you use. If you wish to maintain the 

original settings, you may wish to download the .pdf version, which can then be printed 

using the freely available Adobe Acrobat Reader®. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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PREFACE 

On December 8, 1993, Title VI of the North American Free Trade Agreement Implementation 

Act (Pub. L. 103-182, 107 Stat. 2057), also known as the Customs Modernization or “Mod” Act, 

became effective. These provisions amended many sections of the Tariff Act of 1930 and 

related laws. 

Two new concepts that emerge from the Mod Act are “informed compliance” and “shared 

responsibility,” which are premised on the idea that in order to maximize voluntary compliance 

with laws and regulations of U.S. Customs and Border Protection, the trade community needs to 

be clearly and completely informed of its legal obligations. Accordingly, the Mod Act imposes a 

greater obligation on CBP to provide the public with improved information concerning the trade 

community's rights and responsibilities under customs regulations and related laws. In addition, 

both the trade and U.S. Customs and Border Protection share responsibility for carrying out 

these requirements. For example, under Section 484 of the Tariff Act, as amended (19 U.S.C. 

1484), the importer of record is responsible for using reasonable care to enter, classify and 

determine the value of imported merchandise and to provide any other information necessary to 

enable U.S. Customs and Border Protection to properly assess duties, collect accurate 

statistics, and determine whether other applicable legal requirements, if any, have been met. 

CBP is then responsible for fixing the final classification and value of the merchandise. An 

importer of record’s failure to exercise reasonable care could delay release of the merchandise 

and, in some cases, could result in the imposition of penalties. 

Regulations and Rulings (RR) of the Office of International Trade has been given a major role in 

meeting the informed compliance responsibilities of U.S. Customs and Border Protection. In 

order to provide information to the public, CBP has issued a series of informed compliance 

publications on new or revised requirements, regulations or procedures, and a variety of 

classification and valuation issues. 

This publication, prepared by the National Commodity Specialist Division, ORR, is a guide to 

certain provisions of Harmonized Tariff Schedule of the United States (HTSUS) heading 6110. 

“Classification of Knit to Shape Garments under HTSUS Heading 6110” provides guidance 

regarding the classification of imported merchandise. We sincerely hope that this material, 

together with seminars and increased access to rulings of U.S. Customs and Border Protection, 

will help the trade community to improve voluntary compliance with customs laws and to 

understand the relevant administrative processes. 

The material in this publication is provided for general information purposes only. Because 

many complicated factors can be involved in customs issues, an importer may wish to obtain a 

ruling under Regulations of U.S. Customs and Border Protection, 19 C.F.R. Part 177, or to 

obtain advice from an expert who specializes in customs matters, for example, a licensed 

customs broker, attorney or consultant. 

Comments and suggestions are welcomed and should be addressed to the Executive Director, 

Regulations and Rulings, Office of International Trade, U.S. Customs and Border Protection, 

1300 Pennsylvania Avenue, NW, (Mint Annex), Washington, D.C. 20229. 

Sandra L. Bell 

Executive Director, Regulations and Rulings 

Office of International Trade 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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DEFINITION AND APPLICABLE TARIFF PROVISIONS...........................7

CERTAIN CHINESE-ORIGIN KNIT TO SHAPE GARMENTS - 

EXCLUSION FROM QUOTA.......................................................................7

SUMMARY OF STATISTICAL NOTE 6 TO CHAPTER 61, HTSUS 

REQUIREMENTS ........................................................................................8

COMPARISON CHART: CHAPTER 61, STATISTICAL NOTE 6 VERSUS 

19 C.F.R. 102.21..........................................................................................9

ANALYZING KNIT TO SHAPE GARMENTS FOR PURPOSES OF 

STATISTICAL NOTE 6................................................................................9

Components............................................................................................................... 10

Necklines and Armholes............................................................................................. 11

Shaping by Full Fashion Knitting................................................................................ 11

Shaping with Lines of Demarcation............................................................................ 12

Collars and Neckbands .............................................................................................. 14

Capping...................................................................................................................... 15

Plackets...................................................................................................................... 16

Pockets ...................................................................................................................... 17

Inserts ........................................................................................................................ 18

Cutting........................................................................................................................ 18

Linking and Looping ................................................................................................... 19

Sewing ....................................................................................................................... 19

Other Garment Features ............................................................................................ 20

FREQUENTLY ASKED QUESTIONS.......................................................22

ADDITIONAL INFORMATION...................................................................26

The Internet................................................................................................................ 26

Customs Regulations ................................................................................................. 26

Customs Bulletin ........................................................................................................ 26

Importing into the United States ................................................................................. 27

Informed Compliance Publications............................................................................. 27

Value Publications...................................................................................................... 28

“Your Comments are Important”................................................................................. 29

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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DEFINITION AND APPLICABLE TARIFF PROVISIONS 

Heading 6110 of the Harmonized Tariff Schedule of the United States (HTSUS) 

provides for “Sweaters, pullovers, sweatshirts, waistcoats (vests) and similar articles, 

knitted or crocheted.” Within heading 6110, HTSUS, there are multiple 10-digit 

reporting numbers (statistical suffixes) which provide for “knit to shape articles 

described in Statistical Note 6 to [Chapter 61]”, HTSUS. 

Statistical Note 6 to Chapter 61, HTSUS defines “knit to shape” for these 10-digit 

reporting numbers, stating: 

For the purposes of statistical reporting under heading 6110, the term “knit to 

shape” means garments knit to shape on flat-knitting machines, having a

stitch count exceeding 9 stitches per 2 centimeters, but less than or equal

to 18 stitches per 2 centimeters, measured on the outer surface of the fabric, in 

the direction in which the stitches are formed. For purposes of this statistical 

note, in the instances where both knit and purl stitches are usually counted,

the purl stitches will be disregarded, and only the knit stitches on the outer 

surface of the fabric will be counted. All of the garment’s components, which 

include, but are not limited to, collars, plackets, cuffs, waistbands and pockets, 

are knit to shape. All of the components are assembled by looping and

linking, including the side seams.

 The following 10-digit reporting numbers within heading 6110, HTSUS, provide 

for “knit to shape” articles: 

6110.20.1026 6110.20.1031 6110.20.2067 

6110.20.2077 6110.30.2051 6110.30.2061 

6110.30.3051 6110.30.3057 6110.90.9067 

6110.90.9071 6110.90.9079 6110.90.9081 

Garments classified in these 10-digit provisions are covered by textile categories 

338/339/638/639. 

CERTAIN CHINESE-ORIGIN KNIT TO SHAPE GARMENTS - 

EXCLUSION FROM QUOTA 

The Memorandum of Understanding (MOU) between the United States of 

America and the People’s Republic of China, implemented on January 1, 2006, for 

goods exported on or after that date through December 31, 2008, allows for the 

exclusion from quota of knit to shape articles made in China classified in the 10-digit 

reporting numbers set forth above. Consequently, while these Chinese-origin articles 

are covered by textile categories 338/339/638/639, they are not subject to quota. 

Nevertheless, garments made in China that do not meet the requirements of Statistical 

Note 6 to Chapter 61, HTSUS, are not classified in any of the HTSUS subheadings 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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listed above and are subject to quota. Additionally, non-Chinese origin articles 

classified in these 10-digit reporting numbers may be subject to quota. Quota and visa 

requirements are the result of international agreements that are subject to frequent 

renegotiations and changes. To obtain the most current information on quota and visa 

requirements applicable to this merchandise, we suggest you check, close to the time of 

shipment, the “Textile Status Report for Absolute Quotas” which is available on our web 

site at www.cbp.gov. 

CBP emphasizes that the exception from quota only applies to Chinese-origin 

garments classified in the 10-digit reporting numbers set forth above. Articles that are 

not classified in these provisions because they fail to meet the terms of Heading 6110, 

its subheadings, or Statistical Note 6 are not excluded from quota as “knit to shape” 

articles. For example, Heading 6110, HTSUS, does not provide for lower body 

garments and, as a result, pants cannot be excluded from quota as knit to shape 

articles. 

SUMMARY OF STATISTICAL NOTE 6 TO CHAPTER 61, HTSUS 

REQUIREMENTS 

 The garment must be classified in heading 6110 as an “Other” garment. 

o Vests and tank tops are not included. 

o Only specific HTSUS numbers in chief weight of cotton and man-made fibers are 

involved. 

 All components must be knit to shape on flat-bed knitting machines. 

 All components must be assembled by linking and looping. 

 The special stitch counting rule for Statistical Note 6 applies. The stitch count of 

the garment under the special rule must be more than 9 stitches per 2 

centimeters but must not exceed 18 stitches per 2 centimeters.

PLEASE NOTE: The guidance set forth in this Informed Compliance Publication 

("ICP") is applicable only in determining whether a garment is classified as a "knit to 

shape" garment for purposes of statistical reporting under heading 6110, HTSUS. 

The material in this publication is provided for general information purposes only. 

While this publication provides general information on the subject, determinations on 

whether a garment is classified as a "knit to shape" garment for purposes of statistical 

reporting under heading 6110, HTSUS, must be based on the text of Statistical Note 6 

to Chapter 61, HTSUS. CBP cautions importers not to rely on any definition of "knit to 

shape" other than the one set forth in Statistical Note 6 to Chapter 61, HTSUS. 

Note that this ICP is not applicable to country of origin determinations under 19 

C.F.R. 102.21. For general information on this topic, CBP recommends consulting the 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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ICP, What Every Member of the Trade Community Should Know About: Country of 

Origin of Knit to Shape Apparel Products (March 2006).

COMPARISON CHART: CHAPTER 61, STATISTICAL NOTE 6 VERSUS 

19 C.F.R. 102.21 

Chapter 61 Customs Regulations 

Statistical Note 6 19 C.F.R. 102.21 

Used to determine classification

within

Used to determine country

Heading 6110 only. 

All components must be knit to 

shape. 

Components include collar, cuffs, 

waistband, placket, pockets, etc. 

Both neckline and armhole must be 

knit to shape. 

Components must be linked and 

looped. 

Components must be knit on a flatbed machine. 

Specific stitch count limits the 

application of the note. 

 of origin

only.

Major parts must be knit to shape. 

Major parts do not include collar, 

cuffs, waistband, placket, pockets 

etc. 

Either neckline or armhole must be 

knit to shape. 

Method of assembly is not specified.

Type of knitting machine is not 

specified. 

Used for all applicable goods. 

Stitch count is not a limitation. 

ANALYZING KNIT TO SHAPE GARMENTS FOR PURPOSES OF 

STATISTICAL NOTE 6 

Note: when in the following discussion we use terms such as “must have,” or 

“acceptable” or “unacceptable,” we are referring to conditions that must be satisfied in 

order for a garment to be classified under the “knit to shape” provisions described 

above. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Components 

Components include, but are not limited to: 

 Front and back panels and sleeve panels 

 Collars (including neckbands) 

 Plackets (both outside and inside placket sections) 

 Cuffs 

 Waistbands 

 Pockets (including pocket welts and pocket bags) 

 Linings (see FAQ #10, below) 

 Capping 

 Inserts 

 Hoods 

To be considered knit to shape, all components must have: 

 Self-start bottoms 

 Self-finished sides (selvage edges) 

The most common types of 

self-start bottoms are rib 

knit and tubular knit. 

Waste yarn is allowed between finished components (such as is commonly 

seen between collar and cuff components or at the shoulder or sleeve cap). 

 

Waste 

yarn 

 Shoulder with waste yarn Sleeve cap with waste yarn 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Necklines and Armholes

Front and back panels must have self-start bottoms and self-finished sides

and must also have shaping at the FRONT AND BACK necklines and at the

armholes. Sleeves must have self-start bottoms and self-finished sides and must also 

have shaping at the armholes. 

Neckline and armhole shaping may be accomplished by FULL 

FASHION KNITTING or with ACCEPTABLE LINES OF DEMARCATION. 

Shaping by Full Fashion Knitting

The panels are fully shaped on a flat knitting machine by increasing or 

decreasing the number of wales to create the contour of the garment. 

Front panel is shaped and 

has a finished (contoured) 

neckline and armholes. 

Sleeve panel is shaped and 

is contoured at the 

armhole. 

Full fashion 

marks at the 

armhole. 

Fashion marks are formed by 

transferring stitches to 

adjacent needles to create a 

contour. 

Contoured crew neckline. 

ACCEPTABLE

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Shaping with Lines of Demarcation 

 Lines of demarcation must be clear and continuous and created by a visible

change in knit pattern.

ACCEPTABLE

 

 Partial lines of demarcation that do not delineate the full neckline are not

acceptable.

 

 Marker holes that indicate where the collar or neckband will be attached are not

sufficient to delineate the neckline.

 clear 

and continuous lines 

of demarcation 

Center area lacks 

demarcation. 

NOT

Marker holes do 

not delineate a 

neckline. 

NOT ACCEPTABLE

PANEL IS NOT

KNIT TO SHAPE

 ACCEPTABLE

PANEL IS NOT

KNIT TO SHAPE

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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 Waste yarn alone does not delineate a neckline. Whether it is a relatively 

straight neckline (as when the garment has raglan sleeves) or curved (as when 

the garment has set-in sleeves), the neckline must have delineation. Waste

yarn alone is not sufficient to delineate the neckline.

Lines of demarcation at the rear 

neckline of a raglan sleeve garment. 

Waste yarn alone at the rear 

neckline is not sufficient. 

 

 Demarcation that is shown by a change in color alone is not acceptable.

 Acceptable lines of demarcation may also show where a cut is necessary for the 

placket. If the garment has a full front opening, the demarcation must extend to 

the bottom of the panel. 

ACCEPTABLE

The neckline and armholes are 

delineated by a change in the 

color of the yarn (rather than by a 

change in knit pattern.) 

NOT ACCEPTABLE

PANEL IS NOT KNIT TO SHAPE

The line of demarcation 

indicating the front opening 

does not extend through the rib 

knit at the bottom of the panel. 

 NOT ACCEPTABLE

PANEL IS NOT KNIT TO SHAPE

NOT ACCEPTABLE

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Collars and Neckbands 

Collars and neckbands must be knit to shape with a self-start bottom and selffinished sides. Waste yarn that is found between components as they are knit on the 

machine is allowed. 

Waste yarn is shown on 

the neckband. 

Waste yarn is shown on a 

flat knit collar. 

This neckband has a self-start 

bottom and self-finished sides 

(selvage edge) and is knit to 

shape. 

ACCEPTABLE

This neckband does not have a 

self-start bottom and is not knit 

to shape. 

NOT ACCEPTABLE

Self-finished sides (selvage 

edges) are required on all 

components. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Capping 

 

Capping that is formed as strips of knit fabric is not considered “knit to

shape” for purposes of Statistical Note 6. Capping must be shaped on the knitting 

machine with a self-start bottom and self-finished sides to the width and length 

required for the garment. 

Waste yarn 

 

NOT 

ACCEPTABLE

The black section 

does not have a 

self-start bottom 

that is required for 

capping to be 

considered knit to 

shape. 

Shown above are two sections of capping material (black) separated by waste yarn. To 

be considered knit to shape, the capping component (black section) requires a self-start

bottom and self-finished (selvage) sides.

This capping was formed as a 

continuously knit strip without a selfstart bottom. NOT ACCEPTABLE

Capping is used to finish the neckline, 

sleeves, pockets, placket etc. It is considered a 

component of the garment for purposes of 

Statistical Note 6 and must be knit to shape with 

a self-start bottom and self-finished sides. 

Capping at the neckline 

Capping 

The capping material should not unravel 

at both ends. This indicates that the 

component does not have a self-start 

bottom. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Plackets 

Placket components must be knit to shape with self-start bottoms and selffinished sides. This includes the placket tape that may form the inside or outside of the 

placket and the capping that often forms the placket of a zippered opening. Woven

placket components are not acceptable.

. Placket components must be knit 

to shape and linked to the 

garment. 

These placket components 

have a self-start bottom and 

self-finished sides. 

ACCEPTABLE

Cutting placket tape to length is 

NOT

 

Capping forms 

the zippered 

placket. The 

capping must be 

knit to shape with 

a self-start 

bottom and selffinished sides.

 ACCEPTABLE

Placket tape should be knit to the 

length used in the garment with a 

self-start bottom and selffinished sides. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Pockets 

All components that make the pocket must be knit to shape with self-start 

bottoms and self-finished sides. This includes pocket edges, welt edges and any 

capping used to finish the pocket, as well as the pocket bag itself. Waste yarn that is 

found between components as they are knit on the machine is allowed. 

Å

All pockets, including patch 

pockets, kangaroo pockets, 

pouch pockets, etc., must be 

knit to shape and linked to the 

garment.

Pocket

 

 edgings and pocket welts

must also be knit to shape. 

Cutting to width or length is not 

allowed.

Pocket bags are the inside portion of the 

pocket. They may be constructed in various 

ways but they must have self- start bottoms 

and self-finished sides and they must be 

assembled by linking or looping. Sewing is not 

allowed. 

Two pocket bags showing waste yarn between 

components. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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Inserts 

Inserts are components that complete a panel or another component. They 

must be knit to shape with self-start bottoms and self-finished sides and must be linked 

and looped onto the garment. 

Triangular insert at the center 

neckline has been knit to 

shape. 

Side panel insert has been knit 

to shape with full fashion marks 

at the armhole. 

ACCEPTABLE ACCEPTABLE

Cutting 

Cutting a component is not allowed, with two exceptions: 

 Cutting along acceptable clear and continuous lines of demarcation at the 

neckline, armhole, center placket or pocket opening is acceptable. (see HQ 

968116) 

 Cutting to form the shoulder slope is allowed. The shoulder seam may be 

reinforced with overlock stitching (and reinforcement tape) but the shoulder

seam must also be linked or looped. (see HQ 968116) 

 Plackets, pocket edges, neckbands, collars, waistbands, capping, etc. must be 

knit to shape and length. Cutting to length is not allowed. 

The shoulder slope has been 

shaped. The shoulder seams 

have been assembled by linking 

and reinforced with overlock 

stitching. 

ACCEPTABLE

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

Linking and Looping 

All components must be linked and looped. Linking and looping is used to attach 

panels at the shoulders, armholes, and side seams and to attach neckbands, placket 

components, capping, patch pockets, pocket edges and pocket welts, pocket bags, 

waistbands, collars, cuffs, etc. 

Linking and looping stitches appear as a series of chain stitches along a 

seam or where a component is joined. The linking and looping stitch uses the same 

yarn that is used to knit the garment. 

Linking/looping Linking / chain stitch 

 

Linking and looping stitches 

Sewing 

Sewing to attach components to each other is not allowed. However, the 

following stitching is acceptable: 

 overlock stitching at the inside shoulder seam for reinforcement is 

acceptable as long as the shoulder seam has already been joined by 

linking and looping. 

 Attachment of the zipper 

 Attachment of beads, embroidered appliqués, labels etc. 

 Minor stitching done in a location on the garment where it is not possible 

to link and loop (e.g., the ends of the placket, neckband, pocket welts, 

etc.) (See HQ 968116). 

Looping 

Stitch 

(inside) 

 (inside) 

 (outside)

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

Other Garment Features 

Garments with the following features are not considered knit to shape

This list is not exhaustive, but merely reflects features often found on 

garments that have been examined: 

 Woven components, such as collars, cuffs, plackets, inserts, etc. (see FAQ #11, 

below). This includes woven tape or ribbon sewn as part of the placket. 

 Crocheted or raschel knit components, such as panels, sleeves, inserts, etc. (see 

FAQ #2, below). For example: 

The crocheted piece 

significantly extends 

the upper dimension of 

the front panel. 

The crocheted piece forms 

the shoulders of the 

sleeveless garment. 

The raschel lace 

extends the edge of 

the neckline. 

 NOT

The following features do not exclude a garment from the knit to shape

provisions. This list is not exhaustive, but merely reflects features often 

found on garments that have been examined: 

 Zippers and corresponding woven zipper tape (see FAQ #15, below) 

 Beads or sequins (see FAQ #12, below) 

 Embroidery (see FAQ #12 below and HQ 968116) 

 Buttons and buttonholes (see FAQ #13, below and HQ 968116) 

 Drawstrings 

 Narrow decorative tape covering the inside rear neck seam 

 NOT ACCEPTABLE ACCEPTABLE NOT ACCEPTABLE

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

 Shoulder pads (see FAQ #14, below) 

 Embroidered appliqués 

 Certain narrow crocheted edgings: 

 Elbow patches 

 Half-moon (sweat patch) at the inside rear neckline 

 Ordinary hanger loops 

 Ordinary belt loops 

 Overlays sewn onto a complete garment. The overlay must not be integral to 

the garment, must not be inserted into a seam, and must not extend the 

edges of a garment. (It is strongly suggested that classification guidance 

be sought whenever a possible overlay issue is involved.) 

Narrow crocheted edging 

on a neckline and placket. 

Narrow crocheted 

edging on a neckline 

Narrow crocheted 

edging on a sleeve 

 ACCEPTABLE ACCEPTABLE ACCEPTABLE

This overlay does not change the 

dimensional coverage of the garment. 

 ACCEPTABLE

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

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FREQUENTLY ASKED QUESTIONS 

Q. #1: U.S. Customs and Border Protection (CBP) has previously stated that the flat 

knitting machine includes an automated one. Would a power flat machine also apply, or 

do they have to be knit on a hand powered knitting machine? 

A.: Knit to shape garment components may be made on a power flat-bed knitting 

machine. We want to point out that the definition in Statistical Note 6 to Chapter 61, 

HTSUS, which CBP follows, is different from the language in the Memorandum of 

Understanding (MOU). However, there is nothing in either definition to preclude the use 

of power machines. We caution that all of the criteria in Statistical Note 6 to Chapter 61, 

HTSUS, must be met. 

Q. #2: If the garment is crocheted to shape, does it meet the requirements of the 

statistical note? 

A.: No, the note clearly states that the garment is to be knit, not “knit or crocheted.” 

Q. #3: I have a 100 percent cotton tank top that is made in accordance with the 

requirements of Statistical Note 6. Will the garment qualify for the quota exclusion? 

A.: No. In order to qualify for the quota exclusion defined in Statistical Note 6, the 

garment must first be classified in heading 6110. Because tank tops are classified in 

heading 6109, they would not qualify for the quota exclusion. 

Q. #4: The Agreement with China has some very specific language on the knit to shape 

garments. It states, "All components of the garment are knit to shape and all are looped 

and linked, including the side seam and pocket (if any).” This is different from CBP’s 

past definition of knit to shape. CBP had previously stated that the term knit to shape 

applies to any good of which 50 percent or more of the exterior surface area is formed 

by major parts that have been knitted or crocheted directly to the shape used in the 

good, with no consideration being given to patch pockets, appliqués, or the like. Minor 

cutting, trimming, or sewing of those major parts will not affect the determination of 

whether a good is knit to shape. Are these rules applicable? 

A.: No, this new definition is different from our knit to shape rules for country of origin 

determinations under 19 C.F.R. 102.21. Although previous guidance is still valid for 

country of origin determinations under 19 C.F.R. 102.21, it is not applicable to the 

quota-free goods identified by Statistical Note 6 to Chapter 61, HTSUS. For quota 

purposes, CBP cautions importers not to rely on any definition other than the statistical 

note for guidance. 

Q. #5: I have a V-neck pullover that meets the stitch count requirements of Statistical 

Note 6 to Chapter 61, HTSUS. The front and back panels have self-start bottoms, selffinished sides, and contoured armholes with full fashion marks. The sleeves also have 

self-start bottoms, self finish sides and are contoured with full fashion marks. The front 

and back necklines will be cut along clear and continuous lines of demarcation that are 

characterized by a change in knit pattern. All panels will be linked and looped together. 

Will the garment qualify for the quota free provision? 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

A.: Yes, cutting the neckline along clear and continuous lines of demarcation will not 

disqualify an otherwise qualifying garment from the quota free provision. 

Q. #6: The MOU specifies the products excluded as: 

Knit to shape on flat-bed knitting machines, having a stitch count exceeding 9 stitches 

per 2 centimeters, but less than or equal to 18 stitches per 2 centimeters, measured on 

the outer surface of the fabric, in the direction in which the stitches are formed. All of 

the components of the garment are knit to shape and all are looped and linked, 

including the side seam and pocket (if any). 

Please clarify how the stitches should be counted. 

A.: For the purposes of Chapter 61, Note 4 and Chapter 61, Statistical Note 3, CBP has 

not changed its method of counting stitches. However, for the purposes of Chapter 61, 

Statistical Note 6, the method changes for garments where both the knit and purl 

stitches are usually counted. In that instance, only the knit stitches on the outer surface 

will be counted to determine if the garment meets the stitch count requirement of 

Statistical Note 6. This method of stitch counting is to be used only when the 

classification determination within heading 6110 involves the knit to shape statistical 

breakout. 

Q. #7: I have a 100% cotton, jersey knit garment classified in heading 6110 that has 

been knit to shape on a flat-bed knitting machine, having a stitch count of 15 stitches 

per 2 centimeters. I measured the stitches on the outer surface of the fabric in the 

direction in which the stitches are formed. All of the components of the garment are knit 

to shape and are all looped and linked. Will my garment qualify for quota free access? 

A.: Yes, from your description, your garment meets the requirements of Statistical Note 

6 to Chapter 61, HTSUS, and is therefore exempt from quota. 

Q. #8: I have a crew neck, long sleeve knitted garment that has a stitch count of 14 

stitches per 2 cm. The back panel of the garment and the sleeves are knit to shape. 

The front panel is not knit to shape, but is cut to a pattern. Will the garment qualify for 

quota free access? 

A.: Because the front panel is cut and not knit to shape, the garment does not qualify 

for the new statistical provision and would be subject to quota. 

Q. #9: If an otherwise qualifying garment has a patch pocket or spread collar that it not 

knit to shape, will it qualify for quota exclusion? 

A: The note is clear on this issue. All components must be knit to shape. The garment 

will not qualify for quota exclusion because not all components (patch pockets or spread 

collar) are knit to shape. 

Q. #10: For classification purposes, linings are generally discounted. If an otherwise 

qualifying garment has a lining that is either woven or not knit to shape, will the garment 

still qualify for quota exclusion? 

A: The lining is considered a component of the garment. The definition in Statistical 

Note 6 states that all components must be knit to shape. If the lining is either woven or 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

not knit to shape, it will disqualify the garment from quota exclusion. Any knit to shape 

lining must also be looped and linked to the garment. 

Q. #11: If the garment has a woven collar, cuffs and/or placket, but all other 

components of the garment satisfy the definition in Statistical Note 6 to Chapter 61, 

HTSUS, will the garment still qualify for quota exclusion. 

A.: The language is clear. These are components that are not knit to shape. The 

components that are not knit to shape disqualify the garment from the quota free 

exclusion. 

Q. # 12: If an otherwise qualifying garment has an embroidery, beads or sequins, will 

the garment still qualify for the quota exclusion? 

A.: Yes, the embroidery, beads, or sequins will not disqualify the garment from the 

quota free provision, as they are not components. 

Q. #13: If an otherwise qualifying garment has buttons and buttonholes, will the 

garment still qualify for the quota exclusion? 

A.: Yes, the buttons and buttonholes will not disqualify the garment from the quota free 

provision. 

Q. #14: I have an otherwise qualifying garment with sewn-in shoulder pads. Will the 

garment still qualify for quota free treatment? 

A.: Yes, the shoulder pads will not disqualify the garment from quota free treatment. 

Q. #15: I have an otherwise qualifying cardigan with a zipper at the front. The zipper is 

sewn onto the garment. Will the garment still qualify for quota free treatment? 

A.: Yes, The sewn on zipper will not disqualify the garment from quota free 

treatment. 

Q. #16: If an otherwise qualifying garment has shoulders that have been trimmed to 

form the shoulder slope, looped and linked, and reinforced with overlock stitching, will 

the garment still qualify for the quota exclusion? 

A.: Yes, trimming the shoulder to form the shoulder slope will not disqualify the garment 

provided the shoulder seam has been linked and looped. The overlock reinforcement 

will not disqualify the garment from the quota exclusion. 

Q. #17: I will be importing garments that meet the requirements of Chapter 61, 

Statistical Note 6. Will it also be necessary for me to obtain a Customs Ruling prior to 

importation in order to clear my shipments? 

A.: No, there is no requirement that a ruling be obtained in order to clear your 

shipments. There have been no changes to Part 177 Customs Regulations concerning 

this issue. However, as stated in Part 177.1, “It is in the interest of the sound 

administration of the Customs and related laws that persons engaging in any 

transaction affected by those laws fully understand the consequences of that 

transaction prior to its consummation.” Therefore, in certain circumstances, it may be 

appropriate to obtain a ruling. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

Q. #18: Earlier this year I entered some knit to shape garments that had an ELVIS 

transmission and were charged to China’s quota. Now that I have reviewed the 

language of the technical correction of Chapter 61, Statistical Note 6, I believe my 

goods should have been quota free. How do I go about removing the quota charge? 

A.: In such a case that an importer believes past imports have been incorrectly entered, 

normal procedures should be followed. The importer should file a post entry claim citing 

the reasons why the goods should be classified under one of the specified quota-free 

6110 subheadings. If approved, the CBP field office, as a normal cause of business, 

will remove the quota charge. 

 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

ADDITIONAL INFORMATION 

The Internet 

The home page of U.S. Customs and Border Protection on the Internet’s World Wide 

Web, provides the trade community with current, relevant information regarding CBP 

operations and items of special interest. The site posts information -- which includes 

proposed regulations, news releases, publications and notices, etc. -- that can be 

searched, read on-line, printed or downloaded to your personal computer. The web site 

was established as a trade-friendly mechanism to assist the importing and exporting 

community. The web site also links to the home pages of many other agencies whose 

importing or exporting regulations that U.S. Customs and Border Protection helps to 

enforce. The web site also contains a wealth of information of interest to a broader 

public than the trade community. For instance, the “Know Before You Go” publication 

and traveler awareness campaign is designed to help educate international travelers. 

 

The web address of U.S. Customs and Border Protection is http://www.cbp.gov

Customs Regulations 

The current edition of Customs and Border Protection Regulations of the United States 

is a loose-leaf, subscription publication available from the Superintendent of 

Documents, U.S. Government Printing Office, Washington, DC 20402; telephone (202) 

512-1800. A bound edition of Title 19, Code of Federal Regulations is also available for 

sale from the same address. All proposed and final regulations are published in the 

Federal Register, which is published daily by the Office of the Federal Register, National 

Archives and Records Administration, and distributed by the Superintendent of 

Documents. Information about on-line access to the Federal Register may be obtained 

by calling (202) 512-1530 between 7 a.m. and 5 p.m. Eastern time. These notices are 

also published in the weekly Customs Bulletin described below. 

Customs Bulletin 

The Customs Bulletin and Decisions (“Customs Bulletin”) is a weekly publication that 

contains decisions, rulings, regulatory proposals, notices and other information of 

interest to the trade community. It also contains decisions issued by the U.S. Court of 

International Trade, as well as customs-related decisions of the U.S. Court of Appeals 

for the Federal Circuit. Each year, the Government Printing Office publishes bound 

volumes of the Customs Bulletin. Subscriptions may be purchased from the 

Superintendent of Documents at the address and phone number listed above. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

Importing into the United States 

This publication provides an overview of the importing process and contains general 

information about import requirements. The current edition of Importing Into the United 

States contains much new and revised material brought about pursuant to the Customs 

Modernization Act (“Mod Act”). The Mod Act has fundamentally altered the relationship 

between importers and U.S. Customs and Border Protection by shifting to the importer 

the legal responsibility for declaring the value, classification, and rate of duty applicable 

to entered merchandise. 

The current edition contains a section entitled "Informed Compliance." A key component 

of informed compliance is the shared responsibility between U.S. Customs and Border 

Protection and the import community, wherein CBP communicates its requirements to 

the importer, and the importer, in turn, uses reasonable care to assure that CBP is 

provided accurate and timely data pertaining to his or her importation. 

Single copies may be obtained from local offices of U.S. Customs and Border 

Protection, or from the Office of Public Affairs, U.S. Customs and Border Protection, 

1300 Pennsylvania Avenue NW, Washington, DC 20229. An on-line version is 

available at the CBP web site. Importing into the United States is also available for 

sale, in single copies or bulk orders, from the Superintendent of Documents by calling 

(202) 512-1800, or by mail from the Superintendent of Documents, Government Printing 

Office, P.O. Box 371954, Pittsburgh, PA 15250-7054. 

Informed Compliance Publications 

U.S. Customs and Border Protection has prepared a number of Informed Compliance 

publications in the “What Every Member of the Trade Community Should Know 

About:...” series. Check the Internet web site http://www.cbp.gov for current 

publications. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

Value Publications 

Customs Valuation under the Trade Agreements Act of 1979 is a 96-page book 

containing a detailed narrative description of the customs valuation system, the customs 

valuation title of the Trade Agreements Act (§402 of the Tariff Act of 1930, as amended 

by the Trade Agreements Act of 1979 (19 U.S.C. §1401a)), the Statement of 

Administrative Action which was sent to the U.S. Congress in conjunction with the TAA, 

regulations (19 C.F.R. §§152.000-152.108) implementing the valuation system (a few 

sections of the regulations have been amended subsequent to the publication of the 

book) and questions and answers concerning the valuation system. 

Customs Valuation Encyclopedia (with updates) is comprised of relevant statutory 

provisions, CBP Regulations implementing the statute, portions of the Customs 

Valuation Code, judicial precedent, and administrative rulings involving application of 

valuation law. A copy may be purchased for a nominal charge from the Superintendent 

of Documents, Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-

7054. This publication is also available on the Internet web site of U.S. Customs and 

Border Protection. 

The information provided in this publication is for general information 

purposes only. Recognizing that many complicated factors may be 

involved in customs issues, an importer may wish to obtain a ruling under 

CBP Regulations, 19 C.F.R. Part 177, or obtain advice from an expert 

(such as a licensed Customs Broker, attorney or consultant) who 

specializes in customs matters. Reliance solely on the general 

information in this pamphlet may not be considered reasonable care.

Additional information may also be obtained from U.S. Customs and Border Protection 

ports of entry. Please consult your telephone directory for an office near you. The 

listing will be found under U.S. Government, Department of Homeland Security. 

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Classification of Knit to Shape Garments under HTSUS Heading 6110 

May 2008 

“Your Comments are Important” 

The Small Business and Regulatory Enforcement Ombudsman and 10 regional 

Fairness Boards were established to receive comments from small businesses about 

Federal agency enforcement activities and rate each agency’s responsiveness to small 

business. If you wish to comment on the enforcement actions of U.S. Customs and 

Border Protection, call 1-888-REG-FAIR (1-888-734-3247). 

REPORT SMUGGLING 1-800-BE-ALERT OR 1-800-NO-DROGA 

Visit our Internet web site: http://www.cbp.gov

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