Magid Glove & Safety Manufacturing Co. LLC v. United States ( 2023 )

Case: 22-1793 Document: 41 Page: 1 Filed: 12/06/2023
United States Court of Appeals
for the Federal Circuit
______________________
MAGID GLOVE & SAFETY MANUFACTURING CO.
LLC,
Plaintiff-Appellant
v.
UNITED STATES,
Defendant-Appellee
______________________
2022-1793
______________________
Appeal from the United States Court of International
Trade in No. 1:16-cv-00150-TCS, Senior Judge Timothy C.
Stanceu.
______________________
Decided: December 6, 2023
______________________
LAWRENCE FRIEDMAN, Barnes, Richardson & Colburn,
LLP, Chicago, IL, argued for plaintiff-appellant.
MARCELLA POWELL, Commercial Litigation Branch,
Civil Division, Department of Justice, New York, NY, ar-
gued for defendant-appellee. Also represented by BRIAN M.
BOYNTON, AIMEE LEE, PATRICIA M. MCCARTHY, JUSTIN
REINHART MILLER; PAULA S. SMITH, Office of the Assistant
Chief Counsel, United States Bureau of Customs and Bor-
der Protection, United States Department of Homeland Se-
curity, New York, NY.
______________________
Case: 22-1793 Document: 41 Page: 2 Filed: 12/06/2023
2 MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US
Before MOORE, Chief Judge, REYNA and TARANTO, Circuit
Judges.
REYNA, Circuit Judge.
Magid Glove & Safety Manufacturing Co. LLC
(“Magid”) appeals a decision of the United States Court of
International Trade regarding the tariff classification of
certain knit gloves with partial plastic coating. Because we
conclude that the gloves are properly classified under head-
ing 6116 of the Harmonized Tariff Schedule of the United
States, we affirm.
HARMONIZED TARIFF SCHEDULE FRAMEWORK
The Harmonized Tariff Schedule of the United States
(“HTSUS”) 1 governs the classification of imported mer-
chandise. Schlumberger Tech. Corp. v. United States, 845
F.3d 1158, 1163 (Fed. Cir. 2017). The HTSUS is organized
by four-digit headings, and each heading may contain one
or more six-digit or eight-digit subheadings. See Orlando
Food Corp. v. United States, 140 F.3d 1437, 1439 (Fed. Cir.
1998). The headings set forth general categories of mer-
chandise, while the subheadings provide a more particular-
ized division of the merchandise within each category.
Wilton Indus., Inc. v. United States, 741 F.3d 1263, 1266
(Fed. Cir. 2013). The headings and subheadings are enu-
merated in Chapters 1 through 99 across various sections
of the HTSUS. See R.T. Foods, Inc. v. United States, 757
F.3d 1349, 1353 (Fed. Cir. 2014). The HTSUS further con-
tains, among other things, the “General Rules of Interpre-
tation” (“GRIs”), the “Additional United States Rules of
Interpretation” (“ARIs”), and various section and chapter
notes. Id.1 Because the subject gloves were imported in 2015,
the parties cite to HTSUS (2015) (Rev.1). See, e.g., J.A.
286, 291.
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MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US 3
The GRIs and ARIs govern the interpretation of the
HTSUS provisions to determine proper classification of
merchandise. Carl Zeiss, Inc. v. United States, 195 F.3d
1375, 1379 (Fed. Cir. 1999). The GRIs are applied numer-
ically, such that once proper classification is determined
via a particular GRI, the classification inquiry terminates
and the remaining successive GRIs become inoperative.
StarKist Co. v. United States, 29 F.4th 1359, 1361 (Fed.
Cir. 2022). According to GRI 1, a court first construes the
terms of the heading and any relative section or chapter
notes, to determine whether the merchandise at issue is
classifiable under that heading. Orlando Food, 140 F.3d at
1440. After determining the appropriate heading, the
court then proceeds to identify the appropriate subheading.
See id.; see also GRIs 1 & 6, 2 HTSUS.
BACKGROUND
At issue are eight models of knit textile gloves with par-
tial plastic (polyurethane) coating. The gloves consist of a
shell made of man-made fibers that is directly knitted to
shape on an industrial knitting machine. See Magid Glove
& Safety Mfg. Co. v. United States, 567 F. Supp. 3d 1334,
1337 (Ct. Int’l Trade 2022) (“Decision”). The complete shell
then goes through a dipping process, where the palm and
portions of the fingers are coated with polyurethane. Id. at
1336. Magid markets these gloves for use in automotive,
metal handling, and other industrial and commercial set-
tings. Id. at 1337; J.A. 42–53 (product specifications).
The relevant HTSUS headings and subheadings for the
classification of these imported gloves are:
Heading 6116: Gloves, mittens and mitts,
knitted or crocheted:
2 Under GRI 6, “the classification of goods in the sub-
headings of a heading shall be determined according to the
terms of those subheadings and any related subheading
notes[.]” GRI 6, HTSUS.
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4 MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US
Subheading 6116.10.55: Impregnated,
coated or covered with plastics or rubber:
Other: Without fourchettes: Other: Con-
taining 50 percent or more by weight of cot-
ton, man-made fibers or other textile fibers,
or any combination thereof
J.A. 291.
Heading 3926: Other articles of plastics
and articles of other materials of headings
3901 to 3914:
Subheading 3926.20.10: Articles of apparel
and clothing accessories (including gloves,
mittens and mitts): Gloves, mittens and
mitts: Seamless
J.A. 286.
In January 2015, Magid imported into the United
States two entries of the subject gloves from China and
South Korea. Decision, 567 F. Supp. 3d at 1336. The
United States Customs and Border Protection (“CBP”) clas-
sified the gloves under subheading 6116.10.55 of the
HTSUS, subject to duty at 13.2% ad valorem. Id. at 1338.
After the CBP liquidated the two entries of gloves, Magid
filed a protest, contending that the gloves should have been
classified under subheading 3926.20.10, a duty-free provi-
sion. Id. at 1336, 1338. The CBP denied Magid’s protest.
Id. at 1336.
Magid sued in the United States Court of International
Trade (“CIT”) challenging the denial of its protest. See id.
The parties cross moved for summary judgment. Id. The
CIT determined that the terms of heading 6116, “Gloves
. . . knitted or crocheted,” more appropriately described the
gloves at issue. See, e.g., id. at 1340, 1342–43. The CIT
explained that the terms of heading 3926 did not describe
the subject gloves because, “while comprised in part of a
plastic material (polyurethane), the gloves are not ‘of plas-
tics’ or of other materials of headings 3901 to 3914 (which
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MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US 5
pertain to various plastics and similar substances in pri-
mary forms).” Id. at 1339.
The CIT rejected Magid’s contention that Section XI 3
Note 1(h) excluded the subject gloves from heading 6116.
Id. at 1340–43. Section XI Note 1(h) states that Section XI
does not cover “[w]oven, knitted or crocheted fabrics, felt or
nonwovens, impregnated, coated, covered or laminated
with plastics, or articles thereof, of chapter 39 [(‘Plastics
and Articles Thereof’)].” J.A. 287. According to the CIT,
the “express terms” of this note would exclude the gloves
from heading 6116 “only if they are ‘articles’ of” knitted fab-
rics “impregnated, coated, covered or laminated” with plas-
tics, and “only if those fabrics are classified within”
Chapter 39. Decision, 567 F. Supp. 3d at 1340.
The CIT concluded that the gloves were not of such fab-
rics. Id. at 1342–43. In reaching that conclusion, the CIT
examined provisions in Chapter 39 to determine what “fab-
rics” this chapter may encompass. Id. at 1341. The CIT
found heading 3921 pertinent because it covered “some
plastic sheet or film products that have a textile component
and could be described as ‘fabrics.’” Id. The CIT next con-
sulted relative notes, including the limitation imposed by
Chapter 39 Note 10 4 on the scope of such Chapter 39
3 Section XI (“Textiles and Textile Articles”) covers,
among other chapters, Chapter 61 (“Articles of Apparel and
Clothing Accessories, Knitted or Crocheted”) and the head-
ings within Chapter 61, including heading 6116.
4 Chapter 39 Note 10 provides,
In headings 3920 and 3921, the expression
“plates, sheets, film, foil and strip” applies
only to plates, sheets, film, foil and strip
(other than those of chapter 54) and to
blocks of regular geometric shape, whether
or not printed or otherwise surface-worked,
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6 MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US
“fabrics.” Id. at 1342. Under Chapter 39 Note 10, the CIT
explained, to fall within Chapter 39, “the knitted fabrics
must be in uncut or basic rectangular form and thus cannot
be in more complex shapes.” Id.
Accordingly, the CIT determined that in order to be
considered fabrics of Chapter 39, as required by Section XI
Note 1(h), the fabrics must not only be “impregnated,
coated, covered or laminated with plastics,” but they must
also be “in basic uncut or rectangular form.” Id. (internal
quotations omitted). Because the textile component of the
gloves “is complete when it comes off the [knitting] ma-
chine,” the CIT held that the gloves were not “of” fabrics
encompassed by Chapter 39. Id. at 1342–43 (citation and
internal quotations omitted; alteration in original). The
CIT thus determined that Magid’s gloves were not ex-
cluded from heading 6116 by Section XI Note 1(h). Id.
at 1343.
After concluding that heading 6116 was the appropri-
ate heading, the CIT then applied GRI 6 to arrive at sub-
heading 6116.10.55 for the classification of the subject
gloves. Id. at 1343–44. The CIT accordingly upheld the
CBP’s classification and granted summary judgment in the
government’s favor. Id. at 1344.
Magid timely appealed. We have jurisdiction under 28
U.S.C. § 1295(a)(5).
STANDARD OF REVIEW
We review de novo the CIT’s grant of summary judg-
ment and apply anew the standard used by the CIT to as-
sess the subject classification. Otter Prods., LLC v. United
uncut or cut into rectangles (including
squares) but not further worked (even if
when so cut they become articles ready for
use).
J.A. 283.
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MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US 7
States, 834 F.3d 1369, 1374–75 (Fed. Cir. 2016). Despite
our de novo review, we begin our analysis with the CIT’s
opinion, which “is nearly always the starting point of our
analysis.” Schlumberger, 845 F.3d at 1162 (quoting Nan
Ya Plastics Corp. v. United States, 810 F.3d 1333, 1341
(Fed. Cir. 2016)).
Proper classification of merchandise under the HTSUS
requires a two-step process. First, we ascertain, without
deference, the meaning of the specific terms within the rel-
evant provisions. Orlando, 140 F.3d at 1439. Second, we
determine whether the merchandise at issue falls within
the description of those terms as properly interpreted. Id.This second step presents a factual inquiry that we review
for clear error. Id. Where, as here, there is no factual dis-
pute regarding the nature, structure, and use of the mer-
chandise, the proper classification turns on the first step.
Faus Grp., Inc. v. United States, 581 F.3d 1369, 1372 (Fed.
Cir. 2009).
DISCUSSION
On appeal, Magid challenges the CIT’s classification of
the subject gloves under heading 6116. 5 Appellant Br. 2–
3. To support its proposed alternative heading 3926, Magid
relies on Section XI Note 1(h) and contends that this note
excludes the gloves from heading 6116. Id. at 16–18; Reply
Br. 13–14. According to Magid, the CIT’s interpretation of
this note was erroneous because it failed to apply the rea-
soning in Kalle USA, Inc. v. United States, 923 F.3d 991(Fed. Cir. 2019). Appellant Br. 11; Reply Br. 1. We disa-
gree with Magid’s arguments. For reasons discussed be-
low, we conclude that the subject gloves were appropriately
classified under heading 6116.
5 Magid does not separately challenge classification
under the relevant subheading.
Case: 22-1793 Document: 41 Page: 8 Filed: 12/06/2023
8 MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US
A. Knitted Gloves
To determine the tariff classification of merchandise,
GRI 1 instructs us to consider first the “terms of the head-
ings” and any relative section or chapter notes. GRI 1,
HTSUS (emphasis added). As part of the legal text of the
HTSUS, section and chapter notes have the force of statu-
tory law. See BenQ Am. Corp. v. United States, 646
F.3d 1371, 1376 (Fed. Cir. 2011). Unlike section and chap-
ter notes, the Explanatory Notes 6 are not legally binding,
but they “may be consulted for guidance and are generally
indicative of the proper interpretation of the various
HTSUS provisions.” Id.Absent contrary legislative intent, we construe HTSUS
terms based on their common and commercial meanings,
which we presume to be the same. Carl Zeiss, 195 F.3d at
1379. And when determining which heading is more ap-
propriate for classification, “a court should compare only
the language of the headings and not the language of the
subheadings.” Orlando Food, 140 F.3d at 1440; see also
Schlumberger, 845 F.3d at 1163 (noting that subheadings
“cannot be used to expand the scope of their respective
headings” (internal quotations omitted)).
The subject gloves involve two competing headings:
(1) heading 3926: “Other articles of plastics and articles of
other materials of headings 3901 to 3914”; and (2) head-
ing 6116: “Gloves, mittens and mitts, knitted or crocheted.”
J.A. 286; J.A. 291. Of the two, we conclude that head-
ing 6116 is the appropriate heading.
6 The Explanatory Notes are published by the World
Customs Organization (“WCO”). See Kahrs Int’l, Inc. v.
United States, 713 F.3d 640, 644 n.2 (Fed. Cir. 2013). They
represent the WCO’s official interpretation of the Harmo-
nized Commodity Description and Coding System, the
global system on which the HTSUS is based. Id.Case: 22-1793 Document: 41 Page: 9 Filed: 12/06/2023
MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US 9
Heading 6116 plainly describes “[g]loves . . . knitted.”
J.A. 291. Magid does not seem to dispute that its imported
products are “gloves” and that they are “knitted.” See Ap-
pellant Br. 18. Magid also markets these products as “work
glove[s]” and describes the construction of these products
as “machine knit[ted].” See J.A. 42–53 (product specifica-
tions listing the products as “work glove[s]” and “machine
knit”). So, the record shows that these “gloves” are ma-
chine “knitted,” as heading 6116 describes. Heading 3926,
in contrast, recites “articles of plastics,” and the term
“gloves” only appears in the terms of subheading 3926.20.
J.A. 286. But a proper classification analysis starts with
the terms of the headings, not the subheadings. See Or-
lando Food, 140 F.3d at 1440. In addition, a subheading
cannot expand the plain meaning of the terms of a heading.
See Schlumberger, 845 F.3d at 1163. Here, as the CIT
noted, while the exterior of the gloves has a partial plastic
coating, the gloves are not “of plastics,” as heading 3926 re-
cites. See Decision, 567 F. Supp. 3d at 1339. The terms of
heading 3926 therefore do not describe the subject gloves.
The Explanatory Note to heading 6116 supports this
interpretation. See J.A. 317. This note establishes that
heading 6116 contemplates and covers knitted gloves with
a non-knit component, whether in the shell or as covering.
See id. Following a listing of several subheadings, the ex-
planatory remarks of the note states that heading 6116 “co-
vers all knitted or crocheted gloves,” whether for males or
females, short or long, and it further covers certain gloves
in “unfinished” form. 7 Id. While the remarks provide that
certain gloves with a fur component are excluded from
heading 6116, they do not similarly exclude gloves with a
partial plastic coating. See id. As the CIT explained, this
7 Before the explanatory remarks, the note lists:
6116.10 (“Impregnated, coated or covered with plastics or
rubber, Other:”), 6116.91 (“Of wool or fine animal hair”),
6116.92 (“Of cotton”), 6116.93 (“Of synthetic fibres”), and
6116.99 (“Of other textile materials”). See J.A. 317.
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10 MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US
note thus evidences the legislative intent that the terms of
heading 6116 “include[] as a general matter those [gloves]
to which a non-knitted component, such as a plastic layer,
has been affixed.” Decision, 567 F. Supp. 3d at 1340.
Contrary to Magid’s contention, Section XI Note 1(h)
does not exclude the subject gloves from Section XI and
hence heading 6116. Under Section XI Note 1(h), Sec-
tion XI does not cover “[w]oven, knitted or crocheted fab-
rics, felt or nonwovens, impregnated, coated, covered or
laminated with plastics, or articles thereof, of chapter 39.”
J.A. 287. That is, if the “fabrics” and “articles thereof” fall
within Section XI Note 1(h), they would be excluded from
Section XI by the operation of this note.
To ascertain the scope of such “fabrics” and “articles
thereof” covered by this note, we begin with the plain lan-
guage of Section XI Note 1(h). This note sets forth several
qualifiers that collectively describe and limit the expres-
sion “fabrics.” Id. The first two qualifiers are not in dis-
pute: the “fabrics” must be “[w]oven, knitted or crocheted,”
and they must also be “impregnated, coated, covered or
laminated with plastics.” Id. The ending segment of the
note, however, adds another qualifier which requires the
“fabrics” be “of [C]hapter 39.” Id. We therefore must, as
the CIT did, look to Chapter 39 and locate pertinent provi-
sions that may shed light on what “fabrics” Chapter 39 en-
compasses. This inquiry takes us to heading 3921 because
this heading contemplates “Other plates, sheets, film, foil
and strip, of plastics” combined with “textile materials” or
“textile components.” See, e.g., subheading 3921.13 (cover-
ing items “[c]ombined with textile materials: Products with
textile components . . .”); subheading 3921.90 (covering
items “[c]ombined with textile materials . . .”). Compare
heading 3921 (covering “[o]ther plates, sheets, film, foil and
strip, of plastics”), with heading 3920 (covering “[o]ther
plates, sheets, film, foil and strip, of plastics” that are “not
. . . combined with other materials” (emphasis added)).
And as instructed by GRI 1, we then consider pertinent
notes that inform or limit the scope of heading 3921 and
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MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US 11
the items it covers. See GRI 1, HTSUS. In this regard, we
must give effect to the express limitation set forth in Chap-
ter 39 Note 10, which states that the expression “plates,
sheets, film, foil and strip” of heading 3921 “applies only
to” those that are “uncut or cut into rectangles (including
squares) but not further worked (even if when so cut they
become articles ready for use).” J.A. 283. That is, the “fab-
rics” or textile materials heading 3921 may encompass
must be “uncut or cut into rectangles (including squares)
but not further worked.” Id.
Taking the above into account, we agree with the CIT’s
conclusion that to fall within Section XI Note 1(h), the “fab-
rics” not only must be “impregnated, coated, covered or
laminated with plastics,” they must also be “in basic uncut
or rectangular form.” Decision, 567 F. Supp. 3d at 1342.
The textile fabrics of the subject gloves are undisputedly
not so, because they are in the advanced form of complete
gloves when they come off the knitting machine. J.A. 58
(Magid representative testifying that “[t]he entire glove,
finished glove, comes out of the knitting machine” and then
goes through a dipping process). As the CIT explained, be-
cause the textile fabrics of the gloves are knitted “directly
from yarn [in]to an advanced shape,” these gloves are not
“of” a Chapter 39 fabric. 8 Decision, 567 F. Supp. 3d at
1342–43. The exclusion of Section XI Note 1(h) therefore
does not apply to the subject gloves.
B. Kalle and “Completely Embedded”
Magid contends that the CIT erred in interpreting Sec-
tion XI Note 1(h) by failing to follow Kalle to determine
whether the gloves are “completely embedded” in plastics
and therefore “excluded from HTSUS Section XI if the
gloves are classifiable in Chapter 39.” Reply Br. 1–2 (citing
8 On reply, Magid clarified its arguments and con-
ceded that “[f]or the exclusion [in Section XI Note 1(h)] to
apply, the Note also requires that the fabric or article be
classifiable in Chapter 39.” Reply Br. 2.
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12 MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US
Kalle, 923 F.3d 991); see also Appellant Br. 11–16. In
Magid’s view, Kalle controls “the application of Section XI[]
Note 1(h)” and requires an analysis of the subject gloves
under the “completely embedded” test applied in that case.
Reply Br. 1. We are not persuaded by these arguments.
Kalle involved the interpretation of the term “com-
pletely embedded in plastics,” which appears in Chapter 59
Note 2(a)(3) 9 and addresses coverage and exclusions under
heading 5903. Kalle, 923 F.3d at 994. The merchandise at
issue in Kalle were certain sausage casings “comprised of a
woven textile sheet that is coated with a layer of plastic on
one side.” Id. at 993. The importer contended that the cas-
ings should be classified under heading 3917 as plastics
subject to a lower duty rate, rather than under head-
ing 6307 as made-up textiles. 10 Id. On appeal, the parties
agreed that the interpretation of the term “completely
9 Chapter 59 Note 2(a)(3) provides that,
Heading 59.03 applies to: (a) Textile fab-
rics, impregnated, coated, covered or lami-
nated with plastics, whatever the weight
per square metre and whatever the nature
of the plastic material (compact or cellular),
other than: . . . (3) Products in which the
textile fabric is either completely embed-
ded in plastics or entirely coated or covered
on both sides with such material, provided
that such coating or covering can be seen
with the naked eye with no account being
taken of any resulting change of colour
(Chapter 39).
J.A. 318.
10 The two competing headings in Kalle were: head-
ing 3917, which covers “[t]ubes, pipes and hoses and fit-
tings therefor (for example, joints, elbows, flanges), of
plastics;” and heading 6307, which covers “[o]ther made up
articles, including dress patterns.” Kalle, 923 F.3d at 993.
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MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US 13
embedded in plastics” as used in Chapter 59 Note 2(a)(3)
was determinative. Id. at 994. This court then interpreted
the “completely embedded” language and affirmed the
CIT’s classification. Id. at 995–97.
Kalle’s “completely embedded” test does not apply to
the classification here. None of Kalle’s competing head-
ings, HTSUS chapters, or merchandise, are involved here.
The term “completely embedded” does not appear in Sec-
tion XI Note 1(h) or the two competing headings in this
case. Magid concedes that the text of Chapter 59
Note 2(a)(3) “specifies that th[is] Note applies to Head-
ing 5903,” not to the headings at issue here. Reply Br. 13.
We reject Magid’s attempt to take the interpretation of a
term within Chapter 59 Note 2(a)(3) out of context and ap-
ply it in a case involving different provisions and merchan-
dise. 11
* * *
Magid’s proffered classification approach departs from
GRI 1’s instruction to start a proper classification analysis
by focusing on the language of the headings. The partial
plastic coating does not, as Magid contends, remove the
gloves from heading 6116 and make them classifiable un-
der Chapter 39 as articles of plastics. Further, Magid’s ap-
proach would effectively eviscerate the subheadings under
heading 6116 where the HTSUS drafters specifically ad-
dress the very merchandise Magid imported. See J.A. 291
(subheading 6116.10 covering knitted gloves
11 Notably, Magid relies on Kalle for its appeal, but it
simultaneously requests that this court reconsider Kalle
en banc and overrule that case. Reply Br. 11–16; id. at 11
(Magid contending that Kalle’s “use of Chapter 59[] Note 2
to determine the scope of headings within Chapter 61 ap-
pears to be inconsistent with the instruction in [GRI 1]”).
We find Kalle inapplicable for the classification at issue
and decline to reach the merits of Magid’s en banc request.
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14 MAGID GLOVE & SAFETY MANUFACTURING CO. LLC v. US
“[i]mpregnated, coated or covered with plastics or rubber”).
We reject such an approach.
Accordingly, we conclude that the subject gloves are
properly classified as “Gloves . . . knitted” under head-
ing 6116.
CONCLUSION
Based on the foregoing, we hold that the CIT correctly
classified Magid’s imported gloves under heading 6116.
We have considered Magid’s remaining arguments and
find them unpersuasive. Accordingly, the CIT’s judgment
is affirmed.
AFFIRMED
COSTS
No costs.