Member lesson
See the reasoning behind the question
Sign in with your existing membership to watch.
Sign inApr2019 · Q46 · Practical Exercise
Classifying a crocheted raffia hat in the 2018 HTSUS: why crochet-to-shape points to heading 6505, not plaited or strip-built headgear, and how the material branches lead to 6505.00.9076
Use the 2018 Basic Edition and the original invoice only. The invoice describes a ladies' hat from Italy, crocheted to shape from unspun dyed raffia. It is lined, trimmed with a grosgrain ribbon hat band, and not sewn. Classify it in four steps. Step 1, heading: under GRI 1 the heading terms decide. Heading 6505 covers 'Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed'. A hat crocheted to shape is named directly, and the lining and grosgrain trim do not take it out of 6505. Step 2, construction: heading 6504 covers headgear 'plaited or made by assembling strips of any material'. Crocheting builds the hat from interlocked loops of one continuous material. That is a different construction from plaiting or from assembling strips. Heading 6502 covers only hat shapes, plaited or made by assembling strips, that are not blocked, have no made brims, and are not lined or trimmed. This hat is crocheted, lined and trimmed, so 6502 does not describe it. 'Not sewn' is a subordinate split that appears inside 6502 and 6504. It applies only after one of those headings has been chosen. On its own it does not move a crocheted hat into 6504. Step 3, material: inside 6505.00 'Other', the successive branches are felt headgear from 6501 bodies, then cotton or flax, wool, man-made fibers, and a residual 'Other'. Under GRI 6 these subheadings are compared at the same level. This hat is crocheted, not made from 6501 felt bodies. Its material, as the invoice states, is unspun raffia, a vegetable fiber that is not cotton, flax, wool or man-made fiber. So it falls to the residual subheading 6505.00.90. Step 4, statistical suffix: within 6505.00.90, the suffixes are 30 (70% or more silk), 45 (fine animal hair), 50 (paper yarn), then 'Other', with 76 'Of unspun vegetable fibers' and 89 'Other'. The invoice says unspun raffia, so the suffix is 76. Result: 6505.00.9076, which matches the preserved official answer E. Not taught: the duty rate, the DDP back-calculation, MPF or any total; any 2026 figure, Chapter 99 or Italy-specific measure; any option-by-option walkthrough or answer letter; and the other invoice line (the muscle shirt).
What you will learn
Use the 2018 Basic Edition and the original invoice only. The invoice describes a ladies' hat from Italy, crocheted to shape from unspun dyed raffia. It is lined, trimmed with a grosgrain ribbon hat band, and not sewn. Classify it in four steps. Step 1, heading: under GRI 1 the heading terms decide. Heading 6505 covers 'Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed'. A hat crocheted to shape is named directly, and the lining and grosgrain trim do not take it out of 6505. Step 2, construction: heading 6504 covers headgear 'plaited or made by assembling strips of any material'. Crocheting builds the hat from interlocked loops of one continuous material. That is a different construction from plaiting or from assembling strips. Heading 6502 covers only hat shapes, plaited or made by assembling strips, that are not blocked, have no made brims, and are not lined or trimmed. This hat is crocheted, lined and trimmed, so 6502 does not describe it. 'Not sewn' is a subordinate split that appears inside 6502 and 6504. It applies only after one of those headings has been chosen. On its own it does not move a crocheted hat into 6504. Step 3, material: inside 6505.00 'Other', the successive branches are felt headgear from 6501 bodies, then cotton or flax, wool, man-made fibers, and a residual 'Other'. Under GRI 6 these subheadings are compared at the same level. This hat is crocheted, not made from 6501 felt bodies. Its material, as the invoice states, is unspun raffia, a vegetable fiber that is not cotton, flax, wool or man-made fiber. So it falls to the residual subheading 6505.00.90. Step 4, statistical suffix: within 6505.00.90, the suffixes are 30 (70% or more silk), 45 (fine animal hair), 50 (paper yarn), then 'Other', with 76 'Of unspun vegetable fibers' and 89 'Other'. The invoice says unspun raffia, so the suffix is 76. Result: 6505.00.9076, which matches the preserved official answer E. Not taught: the duty rate, the DDP back-calculation, MPF or any total; any 2026 figure, Chapter 99 or Italy-specific measure; any option-by-option walkthrough or answer letter; and the other invoice line (the muscle shirt).
HTSUS (2018 Basic) Chapter 65, page 65-3, heading 6504 and heading 6505 text; HTSUS (2018 Basic) Chapter 65, page 65-2, heading 6502, and page 65-1, Note 2; HTSUS (2018 Basic) Chapter 65, pages 65-3 to 65-8, successive branches under 6505.00 'Other'; HTSUS (2018 Basic) Chapter 65, page 65-8, subheading 6505.00.90 and statistical suffixes (rate column intentionally not quoted); April 24, 2019 CBLE, Category IX Practical Exercise commercial invoice for questions 45-51 (Sigma COY E.X.T., invoice US001836); April 2019 CBLE cover reference list, question 46 stem, and official answer key line 46 (historical original excerpt) · The exam cover (Series 880, April 24, 2019) lists the 'Harmonized Tariff Schedule of the United States (2018 Basic Edition, No Supplements)'. This lesson uses only the 2018 Basic Edition, Chapter 65: Notes on page 65-1; heading 6502 on page 65-2; heading 6504 on page 65-3; heading 6505 and its branches on pages 65-3 to 65-8; and subheading 6505.00.90 with statistical suffix 76 on page 65-8. The original Category IX commercial invoice is the fact source. This is a historical, classification-only lesson. No duty rate, DDP valuation, MPF, current 2026 schedule, Chapter 99 measure or Italy-specific duty is taught.
Explained using the historical edition for this exam.