CBP Required Lab Analysis to Classify This Athletic Blouse. Here's What It Revealed.

When Dick's Sporting Goods needed certainty on the HTS classification of a new women's athletic blouse from Cambodia, they did what experienced importers do: they requested a binding ruling from CBP before filing a single entry.

What they got back four months later — after lab analysis, a destroyed sample, and a stitch-count test — was Ruling N358843. It settled the question definitively.

What CBP Actually Tested

The garment in question is Style WCG1026 "Calia" — a women's loose-fitting sleeveless blouse made from 92% polyester and 8% elastane knit fabric. It has a partial front opening that zips through a self-fabric stand-up collar, oversized armholes, a straight hemmed bottom with side slits, and a slightly longer back panel.

That product description could plausibly read several ways to someone assigning an HTS code without physical analysis. Knit athletic top. Functional vest. Performance blouse. The heading depends on construction, not marketing copy.

CBP's National Commodity Specialist Division sent the sample to their laboratory. The lab measured the outer surface of the fabric and reported:

• 25 stitches per linear centimeter in the horizontal direction
• 39 stitches per linear centimeter in the vertical direction

This stitch-count analysis is CBP's standard technical record for Chapter 61 garments — it documents the fabric's construction characteristics as part of the classification file. The classification as a blouse under 6106 rather than the broader "other garments" heading 6114 followed from the product's construction details: the partial front opening, the zippered closure through the self-fabric collar, and the loose-fitting sleeveless cut. The ruling states the classification; CBP does not elaborate the reasoning in the ruling letter itself.

The ruling reference: N358843, issued June 16, 2026. CLA-2-61:OT:RR:NC:N3:356. National Import Specialist: Maryalice Nowak, CBP National Commodity Specialist Division, New York.

Why 6106 vs. 6114 Is Not a Trivial Question

Both headings cover women's knit garments of man-made fibers. 6106 covers blouses and shirts; 6114 covers other garments that don't fit a more specific heading. The confirmed duty rate under 6106.20.2010 is 32%. The rate under 6114.30 for women's other garments of man-made fibers has historically been around 28.2% — but verify the current rate at hts.usitc.gov before relying on that figure, as rates can change and the 10-digit statistical suffix matters.

That gap is significant for a major retailer bringing in seasonal athletic wear at volume. But the more important issue is audit exposure: if CBP determines a garment was filed under 6114 when its construction qualifies it as a 6106 blouse, the importer owes back duties on all affected entries. The wrong heading is also the wrong basis for Free Trade Agreement preferential treatment claims, drawback calculations, and any country-of-origin-dependent duty programs.

The design elements — opening type, collar construction, sleeve treatment, fit — determine the specific heading within Chapter 61. A binding ruling locks that determination before the first entry is filed.

The Sample Destruction Notice

CBP's ruling letter includes a line that should get attention from any importer planning this process:

"Your submitted sample was destroyed during this analysis and will not be returned."

This is standard for laboratory analysis requests, but it matters for planning. If you're submitting samples for a binding ruling and the lab analysis is likely (which it will be for any garment where fabric construction determines the classification), submit samples you can spare. Do not submit your only pre-production prototype.

The four-month turnaround — February 12 to June 16 — was driven by the lab analysis queue. Binding rulings on products that don't require lab work come back faster, but apparel classification often does require it.

The Chapter 99 Caveat in Every Recent Ruling

Ruling N358843 includes language that now appears in all CBP classification rulings:

"This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges... This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS."

The 32% stated in this ruling is the general rate of duty under 6106.20.2010. It does not include potential additional duties under Chapter 99, which covers Section 301 tariffs, Section 232 tariffs, and other trade remedy provisions.

Cambodia is not China, so the standard Section 301 Lists do not apply here. But Chapter 99 has been expanding. Any importer relying on this ruling's 32% figure for landed cost calculations should confirm the full Chapter 99 picture at time of entry.

What Binding Rulings Are and When to Request One

A binding ruling under 19 CFR Part 177 is a written determination from CBP that sets the classification, country of origin, or valuation of specific merchandise. Once issued, it is binding on CBP officers at the port of entry — they must accept the ruling's classification unless CBP formally revokes or modifies it.

You do not need a ruling to import. But for products where the heading is genuinely ambiguous — particularly in Chapter 61 and 62 where a single construction detail can shift duty rates by several percentage points — a ruling gives you certainty that a customs broker's professional judgment alone cannot.

The tradeoff:

• Without a ruling: Faster, but classification rests on the broker's interpretation. If CBP disagrees on examination, the importer faces a CF-29 Notice of Action, potential protest, and possible duty underpayment.
• With a ruling: 4-month delay, sample requirements, and lab analysis risk. But CBP must honor the ruling at every subsequent entry for the described merchandise.

For a product like this — a knit athletic blouse where the "blouse vs. other garment" question is fabric-construction-dependent — the ruling was the right call.

How Declaro Reads This

Declaro's engine is trained on 220,000+ CBP CROSS rulings including the full Chapter 61 apparel ruling corpus. When a garment is submitted for classification, the engine identifies which construction details determine the heading and surfaces the rulings where CBP applied those same criteria.

For products that sit at contested heading boundaries — like the 6106/6114 line — Declaro flags the uncertainty rather than returning false confidence. A classification that requires lab analysis to confirm is not one where a model should give you a single answer and move on.

Verify the Ruling Directly

Ruling N358843 is publicly available. All CBP binding rulings are searchable in CROSS:

• CBP CROSS — search ruling N358843: rulings.cbp.gov
• Current HTS duty rates for 6106.20 and 6114.30: hts.usitc.gov → Chapter 61
• Binding ruling request procedure (19 CFR Part 177): CBP Rulings Program

The ruling is two pages and worth reading in full. The stitch-count data and the specific product description are what make it useful — not just as precedent for this garment, but as a model for what CBP's lab analysis actually measures.

Declaro is AI-powered HTS classification and duty recovery for licensed customs broker firms. Built on 220,000+ CBP CROSS rulings. Learn more →