Apparel is the sector where the ordinary tariff never stopped mattering. While most of the schedule drifted toward zero over four decades of negotiation, clothing and footwear kept rates that routinely sit in the high teens and reach the low thirties. An importer who has spent 2026 worrying about sectoral duties on metals may not have noticed that the apparel tariff was already the highest line in their landed cost before any of that started.
That high base changes how everything else lands. A ten-point additional duty on a machine part carrying 2% ordinary duty is a sixfold increase. The same ten points on a garment already carrying 16% is a proportionally smaller shock but a much larger absolute number. This guide covers how Chapters 61, 62 and 64 decide the base rate, what stacks on top of it in 2026, and the de minimis change that removed the workaround a great deal of the trade had come to rely on.
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Why Apparel Rates Never Came Down
Textiles and clothing were carved out of general tariff liberalisation for most of the post-war period, governed instead by a quota system that ran until the Agreement on Textiles and Clothing expired in 2005. Quotas went; the tariffs largely stayed.
The result is a schedule where ordinary duty on garments commonly runs from the low teens to around 32%, with the exact rate turning on fibre content and construction rather than on value or brand. Synthetic fibres generally carry higher rates than cotton, and cotton generally carries higher rates than wool or silk, which is the opposite of what most people expect.
Footwear behaves similarly and is harder still. Chapter 64 rates vary enormously across the chapter, and some subheadings carry compound duties combining an ad valorem percentage with a specific charge per pair. Two shoes that look identical on a shelf can classify differently and carry rates that differ by a factor of several, which is why footwear classification is a specialism rather than a task.
Chapter 61, Chapter 62 and the Knit-Woven Divide
The first question in apparel classification is not what the garment is but how the fabric was made. Chapter 61 covers articles of apparel and clothing accessories that are knitted or crocheted. Chapter 62 covers the same articles when they are not.
That single distinction moves the classification into an entirely different chapter with its own headings, its own notes and its own rates. A knit shirt and a woven shirt are different products for tariff purposes even where they are commercially interchangeable, and the determination is a fabric construction question that has to be answered from the material rather than from the product description.
Within each chapter, the next determinant is fibre content, applied on a chief weight basis. A garment of 60% polyester and 40% cotton is classified as a synthetic garment; change the blend to 55% cotton and the classification and rate both change. Blends near a threshold deserve testing rather than reliance on a supplier’s stated composition, because the entry stands or falls on the actual content.
Getting between two plausible headings is resolved the same way as anywhere else in the schedule, through the General Rules of Interpretation in order. Composite garments and retail sets are where GRI 3(b) essential character does most of its work in this chapter.
- Chapter 61: knitted or crocheted apparel.
- Chapter 62: apparel that is not knitted or crocheted.
- Chapter 64: footwear, with rates that vary widely and some compound duties.
- Within each: fibre content by chief weight, then construction and garment type.
Footwear and the Upper Material Test
Chapter 64 classifies primarily by the constituent material of the upper and then of the outer sole, which is why a canvas sneaker, a leather sneaker and a rubber sneaker sit in three different places despite serving one purpose.
The upper material is determined by the material with the greatest external surface area, excluding accessories and reinforcements. That exclusion is where disputes start: whether a logo overlay, an eyelet stay or a toe cap counts as a reinforcement changes the surface area calculation and can change the heading.
Some subheadings then apply value brackets, so the same shoe classified correctly can carry a different rate depending on whether it lands above or below a stated value per pair. That interacts directly with valuation, because a change in how the entered value is built up can move a shoe across a bracket, which makes customs valuation and classification a single exercise rather than two.
Because the spread across Chapter 64 is so wide and the tests are so specific, this is one of the strongest cases in the whole schedule for fixing the answer in advance. A binding ruling on a footwear construction that will be imported repeatedly pays for itself many times over.
What Stacks on Top in 2026
The Section 301 forced-labour action that took effect on 24 July 2026 reaches most of the origins that dominate apparel and footwear supply. Bangladesh, Cambodia, India, Indonesia, Pakistan and Sri Lanka carry 10%. China, Vietnam and Thailand carry 12.5%. Those duties sit on top of the ordinary rate rather than replacing it.
For Chinese-origin goods the legacy Section 301 lists continue to apply alongside, so an affected garment can carry its ordinary rate, a legacy list rate and the forced-labour rate together. The forced-labour action does exclude goods already subject to Section 232, but that exclusion is largely irrelevant here because apparel and footwear are not covered by the metals or wood programmes.
What is no longer in the stack matters as much. The IEEPA reciprocal duties that hit these origins hard through 2025 were struck down in February 2026 and are no longer collected. An apparel importer still carrying a reciprocal line in a costing model is overstating landed cost, and may have a refund claim for the collection period.
The loss of preference compounds it. Most textiles and apparel subject to textile agreements were statutorily excluded from GSP even when it was in force, so its lapse did not change much for garments, but several of the affected origins have no preference programme available at all. The combined position is a high ordinary rate plus an additional duty with nothing to offset either.
The De Minimis Route Is Closed
For several years a large share of low-value apparel e-commerce entered the United States without duty under the de minimis provision, which admitted shipments valued at or below $800 free of duty and with minimal entry formality. For a category carrying 16% or more in ordinary duty, that was not a convenience but a business model.
It is gone. Duty-free de minimis treatment was suspended for all countries by executive action published on 5 August 2025, and the suspension has been continued since, with further notices published on 25 February 2026 and 9 April 2026. Shipments that previously moved duty free now require ordinary entry and carry ordinary duty.
The operational consequence is larger than the duty. Formal entry brings classification, valuation, origin declaration, record keeping and the merchandise processing fee into a flow that previously had none of them, and it brings the reasonable care standard with it. Sellers who never had a compliance function now need one.
It also changes the arithmetic of consolidation. Where individual parcels were the cheap route, consolidated ocean or air freight with a single formal entry is frequently now cheaper per unit, because the entry cost is spread rather than repeated. That comparison is a full landed cost exercise rather than a freight rate comparison, since the MPF floor alone changes the answer on small consignments.
Where Importers Find Room
Classification review is the first place, because the base rate is where the money is. A garment misclassified into a synthetic heading when it is chief weight cotton, or a shoe misclassified on an upper material determination, can be carrying materially more duty than it owes, and the correction is available going forward and through post-entry routes for recent entries.
Preference claims are the second. Where a supply chain can be structured so goods qualify under a free trade agreement, the ordinary rate goes to zero, and on a 16% or 32% base that is transformative in a way it never is on industrial goods. The yarn-forward rules that apply to textiles under USMCA rules of origin are demanding, but the prize is proportionally larger here than anywhere else.
Valuation is the third and the most overlooked. Where a US brand supplies its own fabric, trim or designs to a contract manufacturer, those are assists and must be declared, but where the buyer pays a buying agent rather than a selling agent, that commission is not dutiable. Both errors are common and they run in opposite directions.
Finally, the duty rate on a re-exported garment is recoverable. Drawback under 19 U.S.C. 1313 returns up to 99% of duty paid on goods that are exported or destroyed, and on an apparel line the amounts involved make duty drawback worth the record keeping it demands.
Frequently Asked Questions
Why are apparel tariffs so high?
Textiles and clothing were largely carved out of general tariff liberalisation and governed by quotas until the Agreement on Textiles and Clothing expired in 2005. The quotas ended and the tariffs mostly stayed. Ordinary duty on garments commonly runs from the low teens to around 32% depending on fibre content and construction.
What decides the tariff rate on a garment?
First whether the fabric is knitted or crocheted, which puts the garment in Chapter 61, or not, which puts it in Chapter 62. Then fibre content on a chief weight basis, then garment type. Synthetic fibres generally carry higher rates than cotton. A blend near a threshold can change chapter, heading and rate.
How is footwear classified?
Chapter 64 classifies primarily by the constituent material of the upper, determined by greatest external surface area excluding accessories and reinforcements, and then by the outer sole. Some subheadings apply value brackets per pair, so the entered value can move a shoe between rates.
Is the $800 de minimis exemption still available?
No. Duty-free de minimis treatment was suspended for all countries by executive action published on 5 August 2025, and the suspension has been continued, with further notices published on 25 February 2026 and 9 April 2026. Shipments that previously entered duty free now require ordinary entry and carry ordinary duty.
What additional duties apply to apparel in 2026?
The Section 301 forced labour action effective 24 July 2026 applies 10% to origins including Bangladesh, Cambodia, India, Indonesia, Pakistan and Sri Lanka, and 12.5% to China, Vietnam and Thailand. For Chinese goods the legacy Section 301 lists apply alongside. The IEEPA reciprocal duties that applied through 2025 were struck down in February 2026 and are no longer collected.
Can apparel duty be recovered?
Yes, on goods that are exported or destroyed. Drawback under 19 U.S.C. 1313 returns up to 99% of the duty paid. Given the size of the ordinary rate on apparel and footwear, the recovery is usually large enough to justify the manufacturing and export record keeping that a claim requires.
