HTS Code 6109.10.00: Cotton Apparel Tariff Guide
Cotton T-shirts are one of the most imported products in the US — and one of the most misclassified. A shipment from Honduras classified under the wrong HTS code pays 16.5% MFN duty when it should pay zero under CAFTA-DR. That's a $33,000 mistake on a $200,000 shipment.
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Search freeWhat Is HTS Code 6109.10.00?
HTS code 6109.10.00 covers T-shirts, singlets, tank tops, and similar garments of cotton, knitted or crocheted. It sits in Chapter 61 of the Harmonized Tariff Schedule, which covers all knitted or crocheted apparel.
Chapter 61 — Knitted or crocheted apparel
Heading 6109 — T-shirts, singlets, tank tops, knitted or crocheted
Subheading 6109.10 — Of cotton
6109.10.00 — The 10-digit US code
The first question when classifying apparel is always knitted or woven. A T-shirt is knit (Chapter 61). A dress shirt with a button placket is usually woven (Chapter 62). Once you're in Chapter 61, fiber content determines the subheading — the chief weight rule applies: if the fabric is more than 50% cotton by weight, it classifies under 6109.10.
6109.10.00 vs. 6109.90.10 — The Classification That Doubles Your Duty
| HTS Code | Fiber | MFN Rate |
|---|---|---|
| 6109.10.00 | Cotton (>50% by weight) | 16.5% |
| 6109.90.10 | Man-made fibers (>50% synthetic) | 32% |
| 6109.90.90 | Other (wool, linen, etc.) | 6% |
A 60/40 cotton-polyester blend classifies under 6109.10.00. A 60/40 polyester-cotton blend classifies under 6109.90.10 — at nearly double the duty rate. This single distinction can swing your landed cost by tens of thousands of dollars on a large shipment. Always verify fiber content percentages against the manufacturer's spec sheet before filing.
What Tariff Rate Do You Pay on Cotton T-Shirts?
The base (MFN) tariff rate for HTS 6109.10.00 is 16.5% ad valorem. That means 16.5% of the customs value — the price you paid for the goods, not including freight or insurance.
On a $150,000 shipment of cotton T-shirts, a 16.5% MFN duty is $24,750 — before any Section 301 add-ons for China-origin goods.
Rate by Origin Country
| Origin | Agreement | Rate | Note |
|---|---|---|---|
| Honduras (CAFTA-DR) | CAFTA-DR | 0% | Yarn-forward rule required |
| Mexico (USMCA) | USMCA | 0% | Yarn-forward rule required |
| Bangladesh | None (MFN) | 16.5% | No FTA available |
| Egypt | None (MFN) | 16.5% | No FTA available |
| China | None + Section 301 | ~24% | [VERIFY RATE] |
CAFTA-DR and 6109.10.00: How Honduras, Guatemala & El Salvador Hit 0%
The Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) eliminates the 16.5% MFN duty on cotton knit shirts — but only if the goods meet the yarn-forward rule of origin.
CAFTA-DR countries for apparel: Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua, Dominican Republic.
The Yarn-Forward Rule in Plain English
To qualify for CAFTA-DR preference on a T-shirt, the yarn, fabric, and finished garment must all be produced within the CAFTA-DR region (or the US):
- Yarn is spun in a CAFTA-DR country or the US
- Fabric is knit from that yarn in the region
- Cutting and sewing happens in a CAFTA-DR country
If a Honduran factory imports Chinese yarn, knits the fabric, and sews the shirt locally — it does not qualify. The yarn-forward requirement is strict.
What CBP Requires at Entry
To claim CAFTA-DR preference, file with a Certificate of Origin and use Special Program Indicator code "P" on your CBP entry. CBP can and does conduct compliance reviews — if you can't substantiate the yarn-forward origin, you'll owe back duties plus interest, and potentially penalties if CBP finds willful misrepresentation.
See how much you're paying — and whether a trade agreement could cut it to 0%.
Compare originsReal Landed Cost Examples: Same Shirt, 4 Different Origins
Assume a shipment of 10,000 cotton T-shirts with a customs value of $2.50/unit = $25,000 total.
Honduras (CAFTA-DR)
MFN: 16.5% | CAFTA-DR: 0%
Requires: yarn-forward origin, Certificate of Origin, SPI "P"
$0
$4,125 saved
Mexico (USMCA)
MFN: 16.5% | USMCA: 0%
Requires: yarn-forward origin, Certificate of Origin, SPI "S"
$0
$4,125 saved
Bangladesh (MFN)
MFN: 16.5% | No preference available
No FTA with Bangladesh — no way around MFN rate
$4,125
China (Section 301)
MFN: 16.5% | Section 301: +7.5% [VERIFY RATE]
Section 301 List 3 rates subject to USTR review
~$6,000
Common Misclassification Traps in Chapter 61
The Chief Weight Rule in Practice
A manufacturer labels a shirt "cotton" on the hangtag but the fabric is actually 48% cotton / 52% polyester by weight. That's a 6109.90.10 classification at 32%, not 6109.10.00 at 16.5%. Best practice: request a fiber content test report (AATCC or equivalent) from your supplier for each new product.
Polo Shirts Are Not 6109
Cotton polo shirts — even if knitted — typically classify under 6105 (men's/boys' shirts, knitted) because they have a collar. Athletic performance garments may fall under 6112. When in doubt, request a binding ruling from CBP before filing.
A binding ruling from CBP gives you classification certainty and protects you from reclassification penalties. Request one at rulings.cbp.gov before your first large shipment.
HTS Code Examples with Real Rates
| HTS Code | Description | Origin | MFN | Preferential | Special |
|---|---|---|---|---|---|
| 6109.10.00 | Cotton knit T-shirts | Honduras (CAFTA-DR) | 16.5% | 0% | — |
| 6109.10.00 | Cotton knit T-shirts | China | 16.5% | — | +7.5% Sec 301 |
| 6109.10.00 | Cotton knit T-shirts | Mexico (USMCA) | 16.5% | 0% | — |
| 6109.90.10 | Synthetic blend knit shirts | Bangladesh | 32% | — | — |
FAQ: HTS 6109 Tariff Questions
What's the duty rate on cotton T-shirts from Honduras?
If the goods meet the CAFTA-DR yarn-forward rule of origin, the duty rate is 0%. File a Certificate of Origin and use SPI code "P" on your CBP entry. CBP can audit compliance — have your yarn sourcing documentation ready.
Does USMCA cover knit cotton shirts from Mexico?
Yes — if the yarn-forward rule is met. The cotton yarn, knit fabric, and finished garment must all be produced in the US-Mexico-Canada region. Use SPI code "S" on entry.
Can I claim CAFTA-DR retroactively if I paid MFN duty?
Yes. File a post-entry amendment (PEA) or a protest (CBP Form 19) within one year of entry liquidation. You'll need the Certificate of Origin documentation in hand when you file.
What happens if CBP reclassifies my 6109.10.00 shipment?
You'll receive a CBP Form 28 (Request for Information) or Form 29 (Notice of Action). You'll owe the duty difference plus interest. Negligent misclassification can result in penalties up to 4x the unpaid duties. Respond promptly with fiber content documentation.
Stop Overpaying on Cotton Apparel Tariffs
HTS code 6109.10.00 carries a 16.5% MFN duty — but if you're sourcing from Honduras, Guatemala, El Salvador, or Mexico and meeting the yarn-forward rule, you should be paying zero. On a $200,000 shipment, that's $33,000 per load.
The keys are correct classification (cotton vs. synthetic blend matters more than most importers realize), the right origin documentation, and staying current on Section 301 rates for China-origin goods.
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