What Every Member of the 

Trade Community Should Know About: 

Classification of 

Children’s Apparel 

AN INFORMED COMPLIANCE PUBLICATION 

JANUARY 2008 
Classification of Children’s Apparel 

January 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 Published: June 1999 

Reviewed With No Changes January 2004 

Revised May 2005 

Reviewed With No Changes June 2006 

Revised January 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 Word97®. 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 Children’s Apparel 

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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 of Regulations and 

Rulings Is entitled “Classification of Children’s Apparel”. It provides guidance regarding the 

classification of these items. 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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INTRODUCTION..........................................................................................7

BABIES’ WEAR HEADINGS 6111 AND 6209............................................7

BABIES’ SETS AND RETAIL SETS...........................................................7

SIZES...........................................................................................................9

STYLING FEATURES ...............................................................................10

GARMENT COVERAGE ...........................................................................10

TWO-PIECE PLAYSUITS..........................................................................12

GARMENT USE.........................................................................................12

INVOICING REQUIREMENTS ..................................................................13

MARKING REQUIREMENTS....................................................................15

GLOSSARY OF CHILDRENS’ WEAR TERMS ........................................15

ADDITIONAL INFORMATION...................................................................19

The Internet................................................................................................................ 19

Customs Regulations ................................................................................................. 19

Customs Bulletin ........................................................................................................ 19

Importing Into the United States................................................................................. 20

Informed Compliance Publications............................................................................. 20

Value Publications...................................................................................................... 21

“Your Comments are Important”................................................................................. 22

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INTRODUCTION 

The purpose of this Informed Compliance publication is to advise importers, 

customs brokers and others of the various issues affecting the importation and tariff 

classification of Children’s apparel. Children's textile apparel is found in Chapters 61 

and 62 of the Harmonized Tariff Schedule of the United States. While classification 

principles for children's wear in many ways emulate classification principles applied to 

adult wearing apparel, certain differences in classification treatment exist between the 

two. Therefore, while a grounding in general apparel classification is a prerequisite for 

understanding children's apparel principles, it is only a beginning. 

BABIES’ WEAR HEADINGS 6111 AND 6209 

Chapter 61, heading 6111 and Chapter 62, heading 6209 are set aside 

exclusively for babies’ textile apparel and apparel accessories. The controlling Chapter 

61, Note 6(b) states, “[a]rticles which are, prima facie, classifiable both in heading 6111 

and in other headings of this chapter are to be classified in heading 6111.” An identical 

note, Chapter 62, Note 4(b), states that Chapter 62 babies’ textile apparel and apparel 

accessories are to be classified in heading 6209. All babies’ garments and clothing 

accessories, with the exception of wool, and non-cotton vegetable fibers, are classified 

in provisions that take a unique “babies’” textile category 239. Wool babies’ garments 

and clothing accessories are classified in provisions that take a unique “babies’” textile 

category 439 whereas babies’ garments and clothing accessories of silk and non-cotton 

vegetable fibers, except those containing 70 percent or more by weight of silk or silk 

waste, are classified in provisions that take a unique “babies’” textile category 839. To 

date, categories 439 and 839 are infrequently used. Heading provisions also exist 

which capture garments and apparel accessories containing 70 percent or more by 

weight of silk or silk waste. These provisions do not take a textile category number. 

BABIES’ SETS AND RETAIL SETS 

Section XI, note 14, HTSUS, provides “Unless the context otherwise requires, 

textile garments of different headings are to be classified in their own headings even if 

put up in sets for retail sale. For the purposes of this note, the expression “textile

garments” means garments of headings 6101 to 6114 and heading 6201 to 6211.” 

Thus, sets of textile garments, which are not provided for as GRI 1 sets, must be 

individually classified in their respective headings even if put up in sets for retail sale. 

For example a girl’s collection consisting of an acrylic sweater, cotton corduroy 

pants and acrylic knit booties is classified separately because Section 11, Note 14 

directs that unless the context otherwise requires (e.g., pajamas, swimwear) textile 

garments of different headings are to be classified separately, even if put up in sets for 

retail sale. The Note defines garments as articles of headings 6101-6114 and 6201-

6211 and omits headwear. Accordingly, the sweater is classified in 6111.30.5030, the 

provision for “other (knitted) garments of synthetic fibers, other, imported as parts of 

sets,” the corduroy pants are classified in 6209.20.5045, the provision for “other (not 

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Classification of Children’s Apparel 

January 2008 

knitted) garments, of cotton, other, imported as parts of sets” and the booties are 

classified in 6111.30.5030, the provision for “other (knitted) garments of synthetic fibers, 

other, imported as parts of sets.” 

Where the goods are classified in the same eight digit subheading, Additional 

U.S. Note 1, to Chapters 61 and 62 is applicable. It states that for purposes of headings 

6111 and 6209, the term “set” means two or more different garments of headings 6111, 

6209 or 6505 (headwear), imported together, of corresponding sizes and intended to be 

worn together by the same person. 

Collections of garments must have the same fabric construction and chief fabric 

weight to qualify for subheadings 6111.20.6020, 6111.30.5020, 6111.90.5020, 

6209.5035, 6209.30.3020 or 6209.90.3020. A set consisting of garments (except 

cotton dresses) of the same fabric normally qualifies for these babies’ sets 

subheadings. 

Subheadings 6111.20.4000 and 6209.20.1000 specifically provide for cotton 

dresses. Pursuant to Section XI, Note 14, referenced above, any coordinating 

garment of headings 6111, 6209 or 6505 imported with the cotton dress will be 

separately classified. However, pursuant to Additional U.S. Note 1, the 

coordinating garment will be classified in subheading 6111.20.6030, 

6111.30.5030, 6111.90.5030, 6209.20.5045 or 6209.30.3030 or 6209.90.3030 as 

it is imported with the cotton dress and is intended to be worn with the dress as a 

set. 

When a collection of garments have different fabric construction, e.g., one piece 

is knit and the other piece is woven and/or one piece is chief weight cotton and the 

other piece is chief weight synthetic fiber, then separate “other, imported as parts of 

sets” provisions usually apply. 

 Goods classified as sets pursuant to Additional U.S. Note 1 are not the same as 

the “goods put up in sets for retail sale” as defined in General Rule of Interpretation 

(GRI) 3(b) (“Retail Set”). GRI 3(b) states that “Mixtures, composite goods consisting of 

different materials or made up of different components, and goods put up in sets for 

retail sale, which cannot be classified by reference to 3(a), shall be classified as if they 

consisted of the material or component which gives them their essential character, 

insofar as this criterion is applicable.” The garments impart the essential character to 

the sets. Accessories such as socks are a mere accent to the set. The presence of 

such articles, which in sizes over 24 months, are found in headings 6115 through 6117, 

and 6212 through 6217, will not cause an otherwise qualifying collection of two or more 

“garments” to fail the classification under the applicable subheading (6111.20.6020, 

6111.30.5020, 6111.90.5020, 6209.5035, 6209.30.3020 or 6209.90.3020 ) providing for 

babies’ sets. 

For example, a boxed set consisting of an acrylic knit sweater, hat and booties, in 

corresponding sizes is classified as a Babies’ Set because the booties are an accessory 

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Classification of Children’s Apparel 

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to the GRI 3(b) “Retail Set.” The hat and sweater are classified in the 6111.30.5020, 

which provides for “Babies’ garments and clothing accessories, knitted crocheted, of 

cotton, other, other, sets.” Similarly, a boy’s dress-up set consisting of woven cotton 

pants, shirt, jacket and bow tie, is a set classified in the 6209.20.5035, which provides 

for “Babies’ garments and clothing accessories, of cotton, other, other, sets” because 

the garments impart the essential character to the set. In these examples, the articles 

are packaged in a manner for sale directly to consumers and the “sets” consist of items 

that meet a particular need, i.e., to clothe a baby. However, a layette set that is sold at 

retail with an additional item such as a blanket, washcloth or rattle, is classified 

separately. Applying GRI principles, the layette set with the additional item(s) fails to 

meet the requirement for “goods put up in sets for retail sale” because the individual 

components no longer share a common purpose. The garments are for wear, the 

blanket is for warmth and the rattle is for amusement.1

SIZES 

There are a number of commonly acknowledged size ranges in children's wear. 

In babies' sizes 0-24 months of age, there is 0-12 months, also called newborn sizes, 

and there is 12-24 months of age, also called infants' sizes. There is a "preemie" size 

range for babies born prematurely. 

After babies, the next size range is toddlers, 2-4, also called 2-4T. Garments for 

boys or girls in this size range have the same numerical designations. The next range 

up is girls 4-6X and boys 4-7. The following range for girls is 7-14 or 7-16. 

In terms of knowing what size range a particular item actually falls in, the sewn in 

fabric label usually provides an accurate indication of the true commercial range. But if 

after examining the item questions about the authenticity of the reported sizing exist, 

certain general standards can be used to assist in the size verification process. While 

standardized and uniform size designations for children’s apparel do not exist, a broad 

consensus exists as to accepted commercial size ranges, for instance, babies’ apparel, 

sizes 0-12 months, commonly equates to a body weight of about 6-18 pounds and a 

height of about 18-27 inches or 48-70 centimeters, while babies sizes 12-24 months 

commonly equates to a body weight of about 18-28 pounds and a height of about 27-35 

inches or 70-90 centimeters. This information represents generalized data and should 

not be construed literally. 

To judge whether an item is bona fide babies' wear it is helpful to actually try the 

garment on an appropriately sized mannequin or child and then evaluate its 

appearance, silhouette and coverage as compared to that of other apparel that is 

 

1

 The Explanatory Notes (ENs) to GRI 3(b) further state that “For the purposes of this Rule, the term ‘goods put up 

in sets for retail sale’ shall be taken to mean goods which: (a) consist of at least two different articles which are, 

prima facie, classifiable in different headings . . . (b) consist of products or articles put up together to meet a 

particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users 

without repacking . . .” For additional information on the application of this rule, see the Informed Compliance 

Publication “Classification of Sets.” 

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properly sized. In other words, see how the article in question, literally, measures up. 

Benchmark the current item against clothing articles whose classification outcomes are 

known. 

When evaluating garments, care should be taken not to mistakenly identify items 

for older children, such as toddlers, as babies, because of differences in quota category 

requirements. 

STYLING FEATURES 

 Garments for children in the commonly acknowledged size ranges often include 

styling and construction features specifically dedicated to the clothing needs of that 

wearer population. For example, styling features for babies normally factor into account 

the distinctive body measurements of developing children as reflected in the various 

size ranges. As an example, babies’ sizes newborn to 12 months and 12- 24 months 

take into account babies’ body proportions as they develop. Design concessions are 

also made to accommodate baby diapers and to provide access to diapers for changing 

purposes. Such garments generally exhibit styling features such as a snap crotch and 

legs, a front opening extending from the neck and down one or both pant legs, an 

oversize neck opening including, perhaps, overlapping or “lapped” fabric at the 

shoulders or snap closures at the shoulders. These garment features address some of 

the physical and lifestyle needs of growing babies. 

GARMENT COVERAGE 

In children's wear classification, often what makes an item what it is for tariff 

purposes is its use in the United States and the parts of the wearer's body that it covers. 

For example, when we speak of sunsuits, washsuits, creepers and rompers, we are 

referring to a class of children's garments which have shorts type coverage below the 

waist and anywhere from full to abbreviated chest coverage above the waist. The fact 

that these articles have this body coverage and that they are used as playwear makes 

classification in certain playsuit tariff provisions which usually require a category 237 

visa appropriate. 

When these same type items have pants coverage below the waist we now have 

coveralls, jumpsuits, or overalls, with the conclusion dependent on the extent and type 

of coverage above the natural waistline. For example, shirt type coverage above the 

waist means the item is a coverall or a jumpsuit, the choice of terms being a marketing 

decision with no classification consequence. 

If the coverage above the waist is abbreviated to the extent that there is a normal 

bib front and possibly a bib back, then the item is a bib overall. Remember, for an item 

to be a playwear bib overall in headings 6103, 6104, 6203, or 6204, it should possess, 

at the least, a significant front bib rise. It should be noted that the bib overall 

illustrations found on page 834 of the Explanatory Notes are not an exhaustive display 

of the types of bib overalls includable here. Garments not possessing overall 

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silhouettes are classifiable elsewhere, specifically, in the 6114 or 6211 provisions for 

sunsuits, washsuits and similar apparel. This same reasoning applies to shortalls which 

differ from overalls only in that they have shorts coverage below the waist. 

The importance of this, from a classification perspective, is that children’s bib 

overalls, shortalls, sunsuits, washsuits and similar apparel and two-piece playsuits are 

classified in tariff provisions corresponding to visa category 237, whereas garments 

outside sizes girls' 2-14, and boys' 2-7, are not. However, knit man-made fiber 

children’s coveralls, jumpsuits and other full body garment tariff provisions constitute a 

notable exception to this general rule and take visa category 659. These classification 

practices, for the most part, pertain only to children’s apparel, boys’ sizes 2-7 and girls’ 

sizes 2-16, or 2-14, for two-piece playsuits. These practices do not extend to boys’ 

sizes 8-20 or men’s wear. Textile visa category 237 applies to some women’s apparel 

in certain limited cases involving cotton and man-made fiber fabrics. A discussion of 

women’s tariff classification principles with respect to visa category 237 and other visa 

categories is outside the scope of this discussion and any reference to women’s apparel 

tariff classification should not be construed as information which is intended to be relied 

upon. 

A unique modesty standard applies to children’s apparel, one which, in certain 

cases, depending on the size and gender of the wearer, is higher or lower than that of 

adult wear. For example, it is acceptable to have a dress with or without an attached 

panty, with the panty visible, in sizes newborn to toddler 4. To merchandise such 

articles, in girls sizes 4-6x and above, as dresses, is not acceptable. 

Also, jumper like garments with modest, uncomplicated A-line styling, in 

corduroy, 10-ounce denim and other winter weight fabrics, are classifiable in tariff 

provisions subject to visa category 359 or 659. This conclusion assumes the items are 

intended for cold weather use with other upper body garments such as blouses or 

turtlenecks. The fact that the garments can, on occasion, be worn alone, is not 

dispositive, because this is not their principal use. 

Another distinction with women’s apparel is made in regard to “divided dresses”, 

items which for practical purposes resemble dresses, except for the culottes type skirt 

division below the waist. Because the legs are not enclosed by a continuous sheath of 

fabric these items are precluded from dress classification. Divided dresses fall within 

the provisions for “other garments,” in headings 6114 and 6211. These garments, 

below the waist, impart a visual impression which obscures the frontal leg separation. 

In women’s wear, divided dresses are classified in headings 6114 and 6211 in 

provisions for playsuits and similar apparel (provided leg coverage does not extend 

below the knee). However, in children’s wear, these garments, which are popular for 

girls 7-16, are classified in the 6114 and 6211 basket provisions, for other wearing 

apparel, other, which are subject to visa categories 359 and 659. Children’s divided 

dresses do not belong to a class or kind of merchandise principally used as one-piece 

playsuits. Children’s playsuits are, by nature, casual and informal in appearance, and 

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Classification of Children’s Apparel 

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have leg separations which are readily apparent when the items are viewed from the 

front. 

TWO-PIECE PLAYSUITS 

Two-piece playsuits are another area where girls' apparel 2-14 and boys' apparel 

2-7 receive different classification treatment from that accorded garments in larger 

sizes. A practice has developed, which allows tops and bottoms, e.g., blouses and 

shorts, possessing certain structural and functional relationships to one another to be 

classified in "playsuit" tariff provisions, which are subject to visa category 237. 

Generally, such playsuits are two-piece physically connected entireties for girls 2-

14 and boys 2-7, such as shirts and shorts having matching buttons and buttonholes, or 

shoulder loops with suspender straps designed to join the two pieces, which are so 

manufactured that the use of one without the other is not practicable. 

In other words, it should not be practicable to wear the shirt and shorts 

separately. The shorts should not be capable of use without the companion shirt. They 

should not possess a substantially elasticized waist which allows the item to be worn 

apart from its coordinated piece with other tops. The most common structural 

connection found is self fabric or elasticized suspender straps which are sewn to the 

rear waistband, pass through loops on the shirt shoulders and fasten to the front waist. 

The idea is that the pants waistband is less than half elasticized and the pants will not 

stay in place without brace straps which serve to support the apparel bottom and are 

supported themselves by loops on the shirt shoulders. 

GARMENT USE 

The concept of principal garment use in the United States is of prime importance 

in the classification of children's apparel. Following HTS principles, items are 

classifiable in the provision which best describes them, after allowing for the 

requirements and restrictions placed on classification by the chapter and section notes, 

the GRI's and the explanatory notes. 

For example, cold weather, padded coveralls, may have some features which are 

similar to those found in one-piece ski-suits. However, without evidence that the 

garment is principally intended for use in skiing the item is classifiable in the provision 

for coveralls, insulated for cold weather protection. This same type reasoning applies to 

polyfill items purported to be ski jackets, overalls and pants. There must be a finding of 

principal use. 

Somewhat different logic applies to fashion playwear with tracksuit styling. Such 

items for small children, sizes newborn to 6x/7, do not qualify as Heading 6112 or 6211 

tracksuits because such items are not "clearly meant to be worn exclusively or mainly in 

the pursuit of sporting activities", as the Explanatory Notes, at page 841, indicate. 

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Determining the correct classification of children's apparel is challenging for both 

the importer and for Customs. Many factors are considered in making this 

determination, indications as to the actual or intended garment use are often provided 

by the importer in the way the merchandise is represented for sale in the marketplace. 

Also to be considered is the firm's reputation in the trade. For instance, is the company 

a known resource for playwear, sleepwear or underwear? Does the company have a 

reputation as a resource for a specific apparel group such as playwear, sleepwear or 

underwear? 

What are the "channels of sale" through which the product is merchandised? 

What particular store buyer places “open to buy” orders for this item, the playwear 

buyer, the sleepwear buyer, or some other store buyer? What do the various “decision 

makers” at each stage of the product’s evolutionary development cycle, beginning with 

prototype development and ending with the product’s sale to the retail consumer, 

consider the item? Usually common unifying elements persist throughout the product 

development and merchandise sale process which identify the item as what it is. 

 The relevant circumstances surrounding the transaction should be scrutinized, 

including, but not limited to, a garment’s construction and an objective evaluation of 

“what it is” according to all interested parties to the transaction, e.g., the designers, the 

manufacturers, the sellers, the retail store buyers, the purchasers and the actual users 

themselves. Familiarity with commercial trade practices within each dynamic market 

segment, e.g., outerwear, playwear, swimwear, and underwear, will lessen the 

likelihood that the garment will be misclassified. 

INVOICING REQUIREMENTS 

The accuracy of the information contained on invoices is an essential element in 

the many new and creative programs Customs has undertaken recently. These 

programs, including, but not limited to, automated entry processing and pre-importation 

review, may provide their benefits to the trade community as a whole, only if the data 

gathered is correct and complete. This concern for invoice accuracy is not new, but, as 

Customs progresses in automation, accuracy becomes indispensable. 

Section 141.86 of the Customs Regulations (19 CFR 141.86) concerns invoicing 

requirements. Subparagraph (a)(3) of the section specifically requires that invoices 

have the following information: 

A detailed description of the merchandise, including the name by which each 

item is known, the grade or quality, and the marks, numbers, and symbols under 

which sold by the seller or manufacturer to the trade in the country of exportation, 

together with the marks and numbers of the packages in which the merchandise 

is packed. 

A "detailed description" is one which enables Customs to easily verify the 

classification of imported merchandise. Accordingly, the invoice description must 

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Classification of Children’s Apparel 

January 2008 

indicate any information which has a direct bearing on the proper classification of the 

imported item. It is incumbent upon the importer of record to ensure that the detailed 

description is present on each invoice. 

Invoices for products of Chapters 61 and 62 should include the following 

information: 

1. The style number, the gender of the wearer, the common and commercial 

designation of each article, and the sizing of the garment. All components, including 

linings, trim, and interlining, must be identified as to composition, construction, individual 

and aggregate weights, and location on the garment. For garments with an outer shell 

of more than one construction or material (textile or non-textile) give the relative 

weights, percentage value, and surface area of each component. For outer shell 

components which are blends of different materials give the relative weights of each 

material in the component. 

2. For two or more garments which are imported together and sold as a unit, 

whether all components are of the same fabric construction, style, color, and 

composition, and of corresponding or compatible size. The invoice should indicate if 

any material appears on one component and not on the other component. 

3. For garments which cover the upper torso, the area of the body which is 

covered and whether the garment has sleeves, a full or partial opening, the location of 

the opening, and the means of closure (e.g., zipper, buttons, snaps). 

4. For knitted garments, the type of knit construction, e.g., jersey, rib, jacquard, 

and whether it is of a specialized fabric, e.g., napped, pile, terry. For garments which 

cover the upper torso, the stitch count per centimeter, in both the horizontal and vertical 

directions, and the stitch count per two centimeters in the direction the stitches were 

formed. 

Importers do not have to provide information that is not necessary to classify a 

specific item. However, they are responsible for giving the Customs Service the 

information that is needed to affix the final classification. Additional information may be 

required for specific merchandise. 

The following information is required on all invoices for infants' cotton knit sets in 

subheading 6111.20.6020, which provides for babies' garments and clothing 

accessories, knitted or crocheted, other, sets. 

1. A detailed description of the set, e.g., 100% cotton jersey turtleneck; 60% 

cotton, 40% polyester, interlock pants. Documentation that the individual 

components of the set are packaged together and intended and capable of being 

worn together, 

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Classification of Children’s Apparel 

January 2008 

2. Sizing. Items must be intended for use by babies, sizes newborn to 24 

months of age, 

3. Unit value. Dutiable value includes all costs, paid or payable, attributable to 

the transaction, including certain uninvoiced costs. Such costs include, and are 

not limited to, payments for assists, royalties, accessories, selling commissions, 

quota charges, 

4. Total value of the shipment, 

5. The terms of sale, and 

6. The country of origin of each component of the set. 

MARKING REQUIREMENTS 

Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides 

that, unless excepted, every article of foreign origin imported into the United States shall 

be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of 

the article will permit, in such a manner as to indicate to the ultimate purchaser in the 

United States the English name of the country of origin of the article. If a babies’ 

clothing set is made in China, it should therefore be marked in English so as to indicate 

this fact (e.g., "Made in China"). 

GLOSSARY OF CHILDRENS’ WEAR TERMS 

The terms “defined” in this glossary are done so from the prospective of their 

tariff classification meaning and any derivative or nomenclature meaning they may have 

with respect to the Harmonized Tariff Schedule of the United States. The glossary 

terms and definitions are not derived primarily from lexicographic sources as the 

purpose here is to provide supplementary information not found in standard reference 

works, but which nonetheless, is useful in the classification of children’s apparel. 

Babies' Textile Apparel and Textile Apparel Accessories - According to the HTSUSA, 

the term “babies” is limited to young children of a body height not exceeding 86 

centimeters. Articles for young children, of a body height not exceeding 86 centimeters, 

are classifiable exclusively in HTSUSA Chapters 61 and 62, in headings 6111 and 

6209. Customs interprets 86 centimeters as equating to the commonly recognized size 

range 0-24 months. 

Baby - A young child, age newborn to 24 months, with a body height not normally 

exceeding 86 centimeters or 34 inches. The term is interchangeable for tariff purposes 

with term "infant". 

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Blanket Sleeper - A full body, footed sleeping garment for a young child which is made 

of brushed or napped, knit man-made fibers, with a zipper extending from the neckline 

to one pant leg. 

Creeper - An abbreviated, short sleeve babies' garment, with a snap crotch and without 

leg coverage which is designed for warm weather use and is usually of jersey, ribbed or 

interlock knit fabric. 

Coverall - A full body garment designed to be worn alone. The item has blouse 

coverage above the waist and pants coverage below the waist. It is interchangeable for 

tariff purposes with the term "jumpsuit". 

Divided Dress- A garment identical to a dress except for a divided skirt, culottes type 

division. The leg separation is not visible when the item is viewed from the front. 

Infant - A young child, age newborn to 24 months (with a body height not normally 

exceeding 86 centimeters or 34 inches). It is interchangeable for tariff purposes with 

the term "baby". 

Infants' Set - Two or more different garments, and/or headwear, imported together, in 

the same sizes, which are intended to be worn together, in sizes newborn to 24 months. 

Jomper - A fashion term for a hybrid garment which contains elements of a romper and 

a jumper. The item resembles a jumper except for a divided skirt, culottes type division 

below the waist. 

Jumper - A sleeveless, dress-like garment, usually with extended or dropped armhole 

openings, designed to be worn with another upper body garment, such as a blouse or 

pullover. The garment construction is such that the item is not intended for use alone. 

Jumpsuit - A full body garment which can be worn alone. The item has at least limited 

blouse coverage above the waist and pants coverage below the waist. It is 

interchangeable for tariff purposes with the term "coverall". 

Overall - A garment identical to pants or trousers except for the addition of a significant 

front bib type rise which extends to the vicinity of the breast and chest sides. 

Pinafore - An apron-like “dress” garment with open sides designed for use with other 

garments such as a shirt, blouse, or dress, and possibly bloomers or a diaper cover. It 

is usually intended for young girls in sizes newborn to 24 months and toddler sizes 2-

4T. 

Playsuit - A general term for a one-piece, abbreviated garment, intended to be worn 

alone as informal attire for casual wear use. The item has shirt type coverage above 

the waist and shorts type coverage below the waist. Rompers, sunsuits and washsuits 

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Classification of Children’s Apparel 

January 2008 

are all considered playsuits for tariff purposes. The term is not to be confused with the 

term two-piece playsuit which is defined elsewhere in the glossary. 

Popover - A fashion term for a pinafore. It is interchangeable for tariff purposes with 

term "pinafore". 

Romper - An abbreviated one piece garment designed to be worn alone. The item has 

shirt or blouse coverage above the waist and shorts coverage below the waist. 

Scooter Skirt - A fashion term for a hybrid garment with a shorts type body and an 

additional fabric flap which is overlaid at the front. The fabric flap extends across the 

garment front, obscuring the leg separation and creating the visual impression, when 

viewed from the front, of a skirt. 

Shortall - A garment identical to shorts except for the addition of a significant bib type 

rise which extends to the vicinity of the breast and chest sides. 

Skeggings - A fashion term for pants style leggings with a sewn-in skirt or peplum at the 

waist. 

Skirt A lower body garment, with coverage, normally extending from the waist to the 

mid-thigh vicinity or below, which envelopes the wearer in an uninterrupted, continuous 

fabric sheath. Fashion may cause the body coverage of the garment to vary somewhat, 

however, it always covers the lower torso. 

Skirtall - A fashion term for a garment which is identical to a skirt except for the addition 

of a significant front bib type rise which extends to the vicinity of the breast and chest 

sides. 

Skort - A fashion term for a divided skirt or culotte. A lower body garment, which 

envelopes the legs in separate fabric sheathes. Imparts the visual impression of a skirt. 

The leg separation is not visible when the item is viewed from the front. 

Skortall - A fashion term for a garment which is identical to a skort except for the 

addition of a significant front bib type rise which extends to the vicinity of the breast and 

chest sides. 

Skromper - A fashion term for a garment which is identical to a romper except for the 

addition of a skirt or peplum. 

Sleep and Play - An infants' wear merchandising term, meaning apparel is suitable for 

use during babies' intermittent sleep and play periods. Such garments are usually 

made of finely knit jersey or interlock fabric and are not specifically constructed as 

sleepwear. 

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Classification of Children’s Apparel 

January 2008 

Stretchsuit - A full body coverall, usually footed, knit, with long sleeves, for young 

children, sizes newborn to 24 months. 

Sunsuit - An abbreviated one piece backless garment designed to be worn alone, with 

limited upper body coverage above the waist and panty or shorts coverage below the 

waist. 

Two-Piece Playsuit - An upper body garment, e.g., a shirt or blouse, and a lower body 

garment, e.g., pants, shorts, overall, shortall, which are structurally connected to one 

another by means of button and buttonhole combinations or suspender strap and shirt 

shoulder loop combinations so that the use of one garment without the other garment is 

not practicable or commercially realistic. 

Washsuit - An abbreviated one piece garment designed to be worn alone, with limited 

upper body coverage above the waist and panty or shorts coverage below the waist. It 

is usually intended for young children in month sizes newborn to 24 months and toddler 

sizes 2-4T. 

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Classification of Children’s Apparel 

January 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 Children’s Apparel 

January 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 Children’s Apparel 

January 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. A copy may be 

obtained from U.S. Customs and Border Protection, Office of Regulations and Rulings, 

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

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 Children’s Apparel 

January 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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