Leggings classified as tights, not trousers, where tariff wording and commercial identity aligned with hosiery treatment.

Imported ladies leggings were held classifiable under Heading 6115 as tights/hosiery rather than under Heading 6104 as trousers. The classification turned on the ordinary meaning of the tariff terms, dictionary definitions, and trade and common commercial understanding: trousers are ordinarily loose-fitting lower-body garments, while leggings are tight-fitting and more akin to tights. The tariff language of Heading 6115 was not limited to inner garments, and a prior governmental decision on similar goods supported the same result. The Revenue's challenge failed, and the goods were treated as hosiery/tights for tariff purposes.

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Issues: Whether imported ladies leggings are classifiable under Heading 6104 as trousers or under Heading 6115 as tights/hosiery.

Analysis: Heading 6104 covers garments such as trousers, which are ordinarily loose-fitting garments for the lower part of the body, whereas Heading 6115 covers panty hose, tights, stockings, socks and other hosiery. The tariff description does not indicate that Heading 6115 is confined to inner garments. Applying the ordinary meaning of the words, dictionary definitions, and the manner in which such garments are understood in trade and common usage, leggings were found to be tight-fitting garments more akin to tights than to trousers. The prior governmental decision in a similar matter also supported classification of leggings as tights under Heading 6115.

Conclusion: The imported goods are classifiable under Heading 6115 and not under Heading 6104; the Revenue's challenge fails.

Ratio Decidendi: Where a tariff entry for hosiery and tights better corresponds to the ordinary commercial and functional identity of leggings than the entry for trousers, the goods must be classified under the entry for tights/hosiery.

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