Customs Guide | Decoding the Tariff Schedule: A Guide to Warm Clothing Imports

With the ongoing cold spell, a variety of winter garments, from trending down jackets and German fleece thermal wear to hard shell jackets (outdoor edition) and cozy sherpa-lined coats, continue to attract strong consumer interest. The following guide breaks down the tariff classification for these imported cold-weather items.

Pursuant to the Import and Export Tariff of the People's Republic of China, clothing is classified first by its construction method: Chapter 61 for knitted or crocheted apparel and accessories, and Chapter 62 for non-knitted or non-crocheted items. The four-digit headings within these chapters are then subdivided by fabric type and garment category, typically progressing from outerwear to innerwear (i.e., from heavier to lighter garments), followed by infant wear, sports wear, and other specialized categories.

I. Down Jackets: Verify “Down Cluster Content” and Beware of Misleading “Tech” Labels

The insulating power of a down jacket derives from down clusters, the three-dimensional, fluffy structures from waterfowl such as ducks and geese. These clusters excel at trapping still air, forming an exceptionally efficient layer of thermal insulation. Since 2021, the updated national standard GB/T 14272-2021 Down Garments has established “down cluster content” as the sole statutory criterion, replacing the previously used and less precise “down content”. A garment qualifies as a “down jacket” only if its down cluster content is 50% or higher, and the filling is exclusively duck or goose down. Typical down jackets are constructed from non-knitted fabrics that have not undergone tanning, coating, or similar finishing processes. These are classified under Heading 62.01 or 62.02. Garments filled with synthetic materials such as “tech down,” “down cotton”, or “microfiber down”are classified as “other cold-weather apparel”. Their appropriate HS code within Chapter 61 or 62 is determined by the fabric’s construction method.

One notably misleading material is “down fiber” (referred to as “waterfowl fiber” in the updated national standard). These are fine filaments separated from feathers that lack the essential down cluster structure and provide poor insulation. They are excluded from the calculation of down cluster content. Therefore, listing only “90% down content” without the mandated down cluster content will result in a review and potential reclassification by Customs.

II. Outdoor Jackets: The Coating Standard vs. The “Outdoor” Label

Defined by a national recommended standard, “Out doctor jackets” are a specific performance apparel category, not merely a fashion label. When a garment is marked as compliant with the national standard GB/T 32614-2023 Outdoor Sportswear - Water Resistant Garments, it signifies that the product is designed to meet stringent performance criteria. These include high levels of moisture vapor transmission rate (MVTR), surface water repellency, and hydrostatic pressure resistance.

Given this performance-based definition, the critical feature for Customs classification of an outdoor jacket is its fabric construction. Genuine outdoor jackets are typically constructed with fabrics that incorporate a plastic, rubber, or polyurethane laminated coating or film. These are classified under Heading 61.13 (knitted) or 62.10 (non-knitted) - categories designated for “Garments, made up of fabrics of heading 59.03 or 59.06”. Conversely, outdoor jackets lacking this distinct functional membrane, regardless of labels such as “mountain edition” or “professional outdoor edition”, are classified as ordinary jackets or windbreakers. They fall under Heading 61.01/61.02 (knitted) or 62.01/62.02 (non-knitted), with the specific HS code subsequently determined by their detailed style and material composition.

III. Thermal Underwear: Unmasking “German Fleece”- It's Synthetic

Market terms like "German Fleece", "Coral Fleece," "Sherpa Fleece," and "Flannel" are widespread. However, regardless of the appealing names, these fabrics are predominantly made from modified acrylic or polyester fibers. Through specialized spinning techniques, they are engineered to produce a fine, dense pile that mimics the feel and warmth of natural animal fleece. While some variants may offer moisture absorption and a resultant warming effect, this is due to the physical adsorption properties of the fibers and not a fundamental upgrade in material. With the rare exception of certain fabrics labeled "flannel" that may incorporate blends of coarse wool, these products are all synthetic fabrics.

Given this composition, sleepwear, loungewear, and base-layer thermal underwear fall under the Customs category of "nightwear and similar articles". For classification, the primary determinant is the construction method: garments that are knitted or crocheted are classified under Heading 61.07 or 61.08, while non-knitted items fall under Heading 62.07 or 62.08. The specific HS code is subsequently determined by a detailed assessment of the garment's style and material composition.