Six-panel structured baseball cap, 100% cotton twill, with adjustable metal buckle strap and embroidered eyelets
Country of origin for this scenario: China.
Recommended HTS code
6505.00.20.60
Other (359)
MEDIUM confidence. Heading 6505 is unambiguous for a woven cotton baseball cap; subheading 6505.00.20 (headwear of cotton, not knitted) and statistical suffix .60 (Other, category 359) are the deepest codes present in the supplied HTS rows and are supported by analogous CBP rulings on woven cotton baseball caps. Confidence is MEDIUM rather than HIGH because the supplied rulings (HQ 087060, HQ 963693, HQ 964184) cite legacy subheadings (6505.90.2500, 6505.90.2060) from the pre-reorganisation schedule, and no on-point ruling cites the current 6505.00.20.60 code directly.
Classification analysis generated on July 15, 2026 from the current Harmonized Tariff Schedule and published CBP rulings, for the product description shown — our analysis, not legal advice.
The question to put to a licensed broker
Do the current CBP binding-ruling precedents for a 100% cotton woven, structured, six-panel baseball cap with an adjustable metal buckle closure confirm classification at 6505.00.20.60 under the reorganised schedule, and is this subheading listed in U.S. note 20(f) triggering the 9903.88.03 Section 301 overlay (+25%) for goods of Chinese origin?
How the classification was reached
GRI Reasoning
GRI 1 — Heading determination
The product is a six-panel structured baseball cap made entirely of 100% cotton twill (a woven textile fabric). Heading 6505 expressly covers "hats and other headgear … made up from … other textile fabric … whether or not lined or trimmed." The Explanatory Note to 6505 (cited in HQ 963693 and HQ 964184) confirms that headgear made up from woven fabric by sewing cut components together falls squarely within this heading. The metal buckle strap and embroidered eyelets are incidental trimmings that do not alter the essential character or remove the article from heading 6505.
GRI 6 — Subheading determination
Working through the 6505.00 subheading hierarchy in the supplied HTS rows:
1. The cap is not a hair-net → exclude 6505.00.01.00.
2. The cap is not felt headgear → exclude 6505.00.04/6505.00.08.
3. The fabric is woven (not knitted or crocheted) → exclude 6505.00.15 (knitted) branch.
4. The cap is of cotton → the applicable branch is "Not knitted: Certified hand-loomed and folklore products; and headwear of cotton" → 6505.00.20, general rate 7.5%, Column 2 rate 37.5%.
5. The cap is not for babies → statistical suffix .60 ("Other (359)") → 6505.00.20.60.
Ruling support
- HQ 087060 (1990): A 100% cotton twill baseball-style cap with adjustable plastic closure was classified in the cotton, not-knitted subheading of 6505 (then 6505.90.2500). Construction details are directly analogous to the subject cap.
- HQ 963693 (2002): A six-panel, woven 100% cotton baseball-style cap with adjustable hook-and-loop strap was classified in the cotton, not-knitted subheading of 6505 (then 6505.90.2060). The current equivalent is 6505.00.20.60.
- HQ 964184 (2002): A six-panel woven cotton baseball cap with adjustable fabric strap was classified at 6505.90.2060, confirming that subheading 6505.90.20 (now 6505.00.20) provides eo nomine for headwear of cotton.
- N020540 (2007): Distinguished on facts (sequin-covered cap classified under 6506 via GRI 3(c)); not applicable here because the subject cap contains no plastics component competing for essential character.
- N350582 (2025): Addresses sample classification under 9811.00.60; not applicable to a standard commercial importation.
Section 301 overlay
The footnote on subheading 6505.00.20 in the supplied HTS data reads: "See 9903.88.03." The supplied Chapter 99 data shows that 9903.88.03 imposes "the duty provided in the applicable subheading + 25%" on articles the product of China listed in U.S. note 20(f). Because origin is China, 9903.88.03 is an additional-overlay flag to verify — if this subheading is enumerated in note 20(f), the total MFN-equivalent duty would be 7.5% + 25% = 32.5%. The broker must confirm current applicability and whether any exclusion applies.
Duty summary (as shown in supplied HTS rows)
| Component | Rate |
|---|---|
| General (MFN) duty | 7.5% |
| Column 2 duty | 37.5% |
| Section 301 overlay (9903.88.03) | +25% (flag to verify) |
Annual duty estimate (MFN only, excluding Section 301)
15,000 units × $2.40 = $36,000 dutiable value × 7.5% = $2,700/year base duty. If 9903.88.03 applies: additional $9,000/year.
Cited CBP rulings
Every ruling below was fetched from CBP’s public CROSS database and verified to exist before this page was published. Links go to the official ruling text.
What it classified: Baseball-style cap of 100% cotton twill fabric with adjustable plastic closure, classified in heading 6505 under the cotton, not-knitted subheading (6505.90.2500).
Why it’s analogous: Materially identical construction: structured baseball-style cap, 100% cotton twill, adjustable back closure. Confirms GRI 1 classification in heading 6505 and the cotton/not-knitted subheading branch now represented by 6505.00.20.
What it classified: Six-panel woven 100% cotton baseball-style cap with adjustable hook-and-loop strap, classified at 6505.90.2060 (cotton, not knitted, other — the predecessor to current 6505.00.20.60).
Why it’s analogous: Nearly identical product: six-panel structured crown, woven cotton fabric, adjustable closure. CBP applied the eo nomine cotton headwear subheading, directly supporting 6505.00.20.60 under the reorganised schedule.
What it classified: Six-panel woven cotton baseball cap with adjustable strap, classified at 6505.90.2060 (cotton, not knitted, other).
Why it’s analogous: Confirms that subheading 6505.90.20 (now 6505.00.20) provides eo nomine for headwear of cotton and applies to six-panel structured baseball caps with adjustable back closures.
What the duty looks like
Duty math shown for illustrative declared values — $2.40 per unit at 15,000 units per year is our assumption for this explainer, not a measurement of anyone's imports. Your numbers will differ.
- Base duty rate (column 1, general)
- 7.5%
- Annual declared value at the illustrative numbers
- $36,000
- Base duty per year (illustrative)
- $2,700
Chapter-99 overlay headings flagged on this code
- 9903.88.03 — The duty provided in the applicable subheading + 25%. Except as provided in headings 9903.88.13, 9903.88.18, 9903.88.33, 9903.88.34, 9903.88.35, 9903.88.36, 9903.88.37, 9903.88.38, 9903.88.40, 9903.88.41, 9903.88.43, 9903.88.45, 9903.88.46, 9903.88.48, 9903.88.56, 9903.88.64, 9903.88.66, 9903.88.67, 9903.88.68, or 9903.88.69, articles the product of China, as provided for in U.S. note 20(e) to this subchapter and as provided for in the subheadings enumerated in U.S. note 20(f)
Overlay applicability depends on origin, entry date, and any active exclusions — verify at entry.
Alternatives considered
The full candidate set from the fetched tariff rows — including rows that would carry a higher duty. Shown so the reasoning is checkable, not to offer a rate menu.
| Code | Description | General rate | Note |
|---|---|---|---|
| 6505.00.25.90 | Other | 7.5% | Present in supplied HTS rows at general rate 7.5%; covers 'Other' not-knitted headgear of cotton, flax or both that falls outside the 'certified hand-loomed and folklore / headwear of cotton' eo nomine provision of 6505.00.20. Applicable only if CBP determines the cap does not qualify under the 6505.00.20 eo nomine description; duty rate is identical (7.5% general, 37.5% Column 2) and the same 9903.88.03 footnote applies. |
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