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October 2025, question 58

Entry / Entry Summary · Rulings and administrative review

High End Store (High End), a U.S. retailer, submitted an administrative ruling request for classification of a woman’s hooded blouse prior to the importation of such blouses. New York Ruling Letter (NY) N123456 was issued to High End, which classified the hooded blouse under subheading 6106.20.2010 of the Harmonized Tariff Schedule of the United States (HTSUS). As part of the decision in NY N123456, the following instruction was included: “[a] copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported.” The manufacturer who produces hooded blouses for High End also produces identical hooded blouses for Discount Retailer, another U.S. retailer. Both High End and Discount Retailer imported the blouses after the issuance of NY N123456. Which of the following statements is TRUE?

  1. Discount Retailer may classify its identical hooded blouses under subheading 6106.20.2010, HTSUS, in reliance upon NY N123456.
  2. In reviewing the entry documentation filed by Discount Retailer, the Center Director may request additional information regarding the imported blouses. If the Center Director determines that Discount Retailer has not obtained a ruling affirming that its hooded blouses are also classifiable under 6106.20.2010, HTSUS, the Center Director is required to suspend liquidation of the entry until Discount Retailer obtains a ruling.
  3. Prior to relying upon NY N123456, issued for High End, Discount Retailer should write to the Port Director at the port of entry and seek clarification as to whether NY N123456 has been modified or revoked.
  4. Once published, NY N123456 is not subject to modification or revocation unlike other administrative ruling letters that do not classify merchandise.
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CBP's answer: A. A: Discount Retailer may classify its identical hooded blouses under subheading 6106.20.2010, HTSUS, in reliance upon NY N123456.

CBP keyed A. Section 177.9(b)(2) says a tariff classification ruling applies to transactions involving articles identical to the sample or description in the ruling, and 177.9(a) says its principle may be cited as authority for transactions involving the same circumstances. Discount Retailer's identical blouses can therefore be classified in 6106.20.2010. B invents a suspension duty, C is wrong because information on modification or revocation is requested from the Commissioner (177.9(c)), not the port director, and D is wrong because 177.12(a) allows rulings to be modified or revoked.

will be applied only with respect to transactions involving articles identical to the sample submitted with the ruling request or to articles whose description is identical to the description set forth in the ruling letter 19 CFR 177.9(b)(2)
may be modified or revoked by an interpretive ruling issued under this section 19 CFR 177.12(a)

Search for: Tariff classification rulings

CBP's key cites: 19 CFR 177.9(a); 19 CFR 159.12(a)(2); 19 CFR 177.12(a)

Question and key from CBP's October 2025 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).