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The tariff classification and eligibility under the United States-Mexico-Canada Agreement (USMCA) of life jackets from Mexico
N360549 April 17, 2026 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification, Trade Agreements TARIFF NO.: 6307.20.0000 Mr. Ricardo Perez 3P Customs Consultants, LLC 1615 Vidal Cantu Road, Pinnacle Industry Center Laredo, TX 78045 RE: The tariff classification and eligibility under the United States-Mexico-Canada Agreement (USMCA) of life jackets from Mexico Dear Mr. Perez: In your letter dated April 8, 2026, you requested a ruling on behalf of your client, Grupo Maquilador de Xalapa, SA de CV, on the tariff classification and eligibility under the United States-Mexico-Canada Agreement (USMCA) for four life jackets. Samples of the life jackets were submitted and will be retained for training purposes. Item 1, Model/sized “Infant” is a textile sleeveless waist-length vest-type personal flotation device (PFD) designed for recreational and/or marine use and intended for an infant less than 30 pounds. The life jacket is composed of three layers: a 92 percent polyester and 8 percent spandex double knit face fabric; a 100 percent polyethylene foam flotation middle layer; and a 100 percent polyester knit dyed inner fabric (touches the infant’s body). The life jacket features a head support panel measuring 12 inches in length by 6 inches in width, a zippered front closure, and one adjustable webbed strap with a plastic side release buckle to tighten around infant’s waist in the front and another between the legs. The head support panel features a sewn webbed strap used to hang the item and a sublimated monster face design with two horns, hair, eyes, cheeks, and five teeth. The inside back lining also features a sublimated Speedo® logo. You state the foam flotation cores are only inserted in the front panels and the head support. At the bottom of the life jacket are three pieces of mesh knitted fabric intended to help the water drain from the jacket. The completed life jacket measures 17 inches in length by 12 inches in width. You also state the PFD is considered a type III U.S. Coast Guard rated safety buoyancy device. The life jacket will be shipped to the United States from Mexico. Item 2, Model/sized “Child” is a textile sleeveless waist-length vest-type personal safety flotation device designed for recreational and/or marine use and intended for a child between 30 and 50 pounds. The life jacket is composed of three layers: a 92 percent polyester and 8 percent spandex double knit face fabric; a 100 percent polyethylene foam flotation middle layer; and a 100 percent polyester knit dyed inner fabric (touches the child’s body). The life jacket features a zippered front closure, two adjustable webbed straps with a plastic side release buckle to tighten around child’s waist in the front and two between the legs, and a webbed strap sewn to the back of the face fabric to hang the item. The life jacket also features a sublimated Speedo® logo on the left front panel and back. At the bottom of the life jacket are three pieces of mesh knitted fabric intended to help the water drain from the jacket. The completed life jacket measures 13 inches in length by 13 inches in width. You state the PFD is considered a type III U.S. Coast Guard rated safety buoyancy device. The life jacket will be shipped to the United States from Mexico. Item 3, Model/sized “Junior” is a sleeveless waist-length vest-type personal safety flotation device designed for recreational and/or marine use and intended for an individual between 50 and 90 pounds. The life jacket is composed of three layers: a 92 percent polyester and 8 percent spandex double knit face fabric; a 100 percent polyethylene flotation foam middle layer; and a 100 percent polyester knit dyed inner fabric (touches the youth’s body). The life jacket features a zippered front closure and two adjustable webbed straps with a p lastic side release buckle to tighten around the waist in the front. The life jacket also features a sublimated Speedo® logo on the left front panel and inside back lining. At the bottom of the life jacket are four pieces of mesh knitted fabric intended to help the water drain from the jacket. The completed life jacket measures 15 inches in length by 17 inches in width. You state the PFD is considered a type III U.S. Coast Guard rated safety buoyancy device. The life jacket will be shipped to the United States from Mexico. Item 4, Model/sized “Adult” is a sleeveless waist-length vest-type personal safety flotation device designed for recreational and/or marine use and intended for an individual over 90 pounds. The life jacket is composed of three layers: a 92 percent polyester and 8 percent spandex double knit face fabric; a 100 percent polyethylene flotation foam middle layer; and a 100 percent polyester knit dyed inner fabric (touches the adult’s body). The life jacket features a zippered front closure and two adjustable webbed straps with a plastic side release buckle to tighten around the waist in the front. The life jacket also features a sublimated Speedo® logo on the left front panel and inside back lining. At the bottom of the life jacket are four pieces of mesh knitted fabric intended to help the water drain from the jacket. The completed life jacket measures 19 inches in length by 22 inches in width. You state the adult model is available in three sizes: XS/S, Med/L, and XL/XXL. You state the PFD is considered a type III U.S. Coast Guard rated safety buoyancy device. The life jacket will be shipped to the United States from Mexico. You state the manufacturing operations for the life jackets are as follows: China: The plastic buckles are produced and shipped to Mexico. 100 percent polyester monofilament yarn, which accounts for 27 percent by weight of the face fabric, is produced and shipped to Mexico The United States: The zippers are produced and shipped to Mexico. The 100 percent polypropylene webbed straps are woven and shipped to Mexico. 100 percent polyester and 100 percent spandex yarn for the mesh fabric are produced and shipped to Mexico. Mexico: 100 percent polyester yarn, which accounts for 65 percent by weight of the face fabric, is produced. 100 percent spandex yarn, which accounts for 8 percent by weight of the face fabric, is produced. Face fabric: 92 percent polyester yarn (65 percent from MX and 27 percent from CN) and 8 percent spandex yarn (from MX) is knitted into fabric, dyed, and sublimated. Inner fabric and bias tape: 100 polyester yarn is produced. Inner fabric and bias tape: 100 percent polyester fabric is knitted and dyed. Mesh fabric: 88 percent polyester and 12 percent spandex fabric is knitted and dyed black. 100 percent polyethylene foam sheets are produced. 100 percent polyester filament sewing thread is produced. The fabrics and foam sheets are cut. The fabrics are sewn together. The webbing straps are measured, cut, and sewn to the fabric panels. The zipper is sewn to the fabrics. Foam sheet is inserted into the life jacket and sewn closed. Plastic buckles are inserted onto the webbing straps. The completed life jacket is packaged and shipped to the United States. ISSUES: What is the tariff classification and USMCA eligibility of the subject merchandise? CLASSIFICATION: You suggested that the “Infant, Child, Junior, and Adult” life jackets should be classified under subheading 6307.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other made up articles, including dress patterns: Lifejackets and lifebelt.” We agree. The duty rate will be 4.5 percent ad valorem. USMCA ELIGIBILITY: The United States-Mexico-Canada Agreement (USMCA) was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (GN) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for
The applicable subheading for the life jackets is 6307.20.0000, HTSUS, dutiable at 4.5 percent ad valorem. Based on the information and sample provided, the life jackets are not eligible for preferential tariff treatment under the USMCA. The holding set forth above applies only to the specific factual situation and merchandise identified in the ruling request. This position is clearly set forth in section 19 CFR 177.9(b)(1). This section states that a ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This