Who is the importer of record under FOB terms?

The buyer or the buyer's customs broker; under DDP the factory arranges import, which is why DDP quotes carry higher prices.

Do samples pay import duty?

Commercial-value samples generally do; proper sample invoices with real values keep the import record clean.

Import Duties and HS Codes for Hi-Vis Workwear from China

Q: Can the factory declare a lower value to reduce duty?

No. Under-declaring is customs fraud; the invoice must state the real transaction value with an accurate garment description.

Buyer answer: Knitted hi-vis T-shirts usually classify under HS 6109, woven safety vests under 6211.43 or 6211.49 (by gender), and jackets under 6201/6202. Duty rates depend on destination, material composition and origin measures — in the US, China-origin apparel can carry additional Section 301 tariffs on top of the base rate. Build landed cost as FOB + freight + insurance + duty + fees + inland, and confirm the exact classification and rate with your customs broker before quoting your own customer: rates and trade measures change.

Export packing: accurate commercial invoices and HS codes keep customs clearance predictable.

Common HS headings for hi-vis garments

Garment	Common heading	Notes
Safety vests (woven, not knitted)	6211.43 / 6211.49	Split by gender; composition and construction decide the 10-digit code
Hi-vis T-shirts and polos (knitted)	6109.10	Cotton vs man-made fiber changes the subheading
Knitted jackets and hoodies	6101 / 6110	Depends on garment construction and material
Woven jackets	6201.40 / 6202.40	Men’s vs women’s; anorak-style codes can differ
Rainwear (waterproof, coated)	6201.91–96 series	Coating type and seam construction matter

Important: classification is a customs-legal question, not a factory decision. The table shows where hi-vis garments commonly land; the controlling 10-digit code, duty rate and any origin measures must be confirmed with your licensed customs broker for your destination.

Building landed cost

Quote your own customers from landed cost, not FOB. The stack for a typical hi-vis order:

Landed cost = FOB value + ocean or air freight + insurance + import duty + customs fees (entry, harbor maintenance, merchandise processing) + broker fee + inland haulage + any port storage.

Two habits keep this number honest: normalize quotes to the same Incoterm (FOB vs EXW vs DDP differ by more than freight), and ask the factory to state what is included, excluded or provisional in writing.

US import specifics

Origin measures. China-origin apparel has carried additional Section 301 tariffs alongside the base duty rate; the applicable list and rate depend on the tariff line and current trade measures, which change — verify at order time.
De minimis. The low-value exemption that once let small parcels enter duty-free has been closed for China-origin goods; plan duties on every commercial shipment.
Documents. Accurate commercial invoice (real garment description, composition, quantity, unit value), packing list and certificate of origin. Generic descriptions like “clothing” slow clearance.

EU and other markets

EU imports add import VAT on top of duty, and garment duty rates depend on composition and construction. EU buyers should also budget for packaging EPR obligations that several member states apply to imported apparel. Middle East, UK and Australian programs typically follow the same pattern: confirm heading, duty and any conformity marks locally, and keep the origin paperwork consistent with the invoice.

Frequently asked questions

Can the factory declare a lower value to reduce duty?

No. Under-declaring is customs fraud, exposes the importer to penalties and voids claims. A factory that suggests it is telling you how it treats every client’s paperwork.

Who is the importer of record?

The buyer (or the buyer’s customs broker) under FOB terms. Under DDP the factory nominates the importer, which is why DDP quotes are higher — they carry the duty and tax risk.

Do samples also pay duty?

Commercial-value samples generally do. Marking samples as “gift” or “$1 value” mis-declares them; proper sample invoices with real values keep your import history clean.

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