Auditing L/C Clauses & Identifying Soft Clauses
Lesson Contents Overview
Learning Objectives
Comprehensive Technical GuidanceTextbook & Training SOP
Lesson 9.4: Auditing L/C Clauses & Identifying Soft Clauses
1. Introduction & The Legal Architecture of Soft Clauses
A Letter of Credit (L/C) is celebrated in international trade as an independent, legally binding undertaking of a commercial bank to pay the exporter against compliant shipping documents. However, this payment guarantee is completely undermined if the credit contains subtle contractual traps known in commercial banking as Soft Clauses.
A Soft Clause is any condition, notation, or requirement inserted into a Letter of Credit (most commonly in Field 46A - Documents Required or Field 47A - Additional Conditions) that makes the issuing bank's payment obligation contingent upon an event, signature, document, or approval that is under the unilateral control of the foreign buyer.
CRITICAL COMMERCIAL PRINCIPLE
Disclaimer: This lesson provides standard operating procedures for professional commercial teams in apparel manufacturing. Legal interpretations may vary based on governing jurisdictions, ICC banking opinions, and active circulars from Bangladesh Bank and international bodies.
2. What Constitutes a Soft Clause Under UCP 600?
Under the International Chamber of Commerce (ICC) Uniform Customs and Practice for Documentary Credits (UCP 600), documentary credits operate on two fundamental principles:
- Article 4 (Independence of Credits): Credits are separate transactions from the underlying sales contracts (PO or PI). Banks are not bound by commercial contracts even if referenced in the credit.
- Article 5 (Documents vs Goods): Banks deal strictly with documents alone, not with the physical goods, manufacturing quality, or commercial performance.
A soft clause bypasses these protections by requiring a document that the factory cannot obtain without the buyer's voluntary cooperation. If the buyer experiences retail slumps, currency shortages, or price deflation, they simply refuse to sign or provide the required document, creating an incurable bank discrepancy.
3. The 10-Step Comprehensive L/C Audit Standard Operating Procedure (SOP)
[ Step 01: Official Advised L/C Intake from Local Advising Bank ]
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[ Step 02: Verification of Core Parameters (Beneficiary Title, Amount, Dates) ]
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[ Step 03: Field 44C (Ship Date) vs Factory Production Schedule Buffer (3-5 Days) ]
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[ Step 04: Field 31D (Expiry) Place of Expiry MUST be BANGLADESH ]
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[ Step 05: Field 43T (Transshipment) MUST State ALLOWED for Sea Shipments ]
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[ Step 06: Field 46A Detailed Document Inventory Audit (Can Factory Procure All?) ]
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[ Step 07: Field 47A Deep Clause Scan for Buyer Signature Vetoes & Document Traps ]
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[ Step 08: Non-Documentary Condition Check Under UCP 600 Article 14(h) ]
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[ Step 09: Field 48 Presentation Window Audit (Minimum 15-21 Days Required) ]
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[ Step 10: Decision Gate ]
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├───────────────────────────────────────────────────┐
▼ [ Discrepancies or Soft Clauses Found ] ▼ [ 100% Clean & Compliant ]
[ Issue Formal SWIFT MT707 Amendment Request ] [ Approve L/C for Production, ]
[ HALT Bulk Cutting Until MT707 Is Advised ] [ BTB Opening & Logistics ]4. Critical Clause Audit Areas & Dangerous Formulations
1. Buyer-Controlled Signature & Inspection Traps
- Dangerous Clause in Field 46A: "Inspection Certificate issued and signed by Buyer's Authorized Representative Mr. David Miller whose signature must match specimen signature card lodged with the Issuing Bank."
- Operational Hazard: If Mr. Miller does not travel to Bangladesh or leaves the buyer company, the factory has zero physical ability to produce this certificate. The negotiating bank in Dhaka cannot verify the signature against the foreign bank's confidential files, causing an automatic rejection.
- Safe Replacement: "Inspection Certificate issued by SGS Bangladesh, Intertek Bangladesh, or Bureau Veritas certifying that goods conform to export specifications prior to shipment."
2. Forwarder Cargo Receipt (FCR) Delivery Hold Traps
- Dangerous Clause in Field 46A: "Forwarder Cargo Receipt (FCR) issued by Buyer's nominated forwarder marked cargo received, with copy of buyer written cargo release approval attached."
- Operational Hazard: The buyer takes physical delivery of garments overseas while instructing their local forwarder to withhold the written release. The factory is left with no transport document to present to the bank.
- Safe Replacement: "Full set Clean On-Board Ocean Bills of Lading consigned to order of negotiating bank and marked Freight Collect."
3. Destination Port & Warehouse Quality Approval Traps
- Dangerous Clause in Field 47A: "Payment shall be released only after the container arrives at buyer's warehouse in Frankfurt, Germany and passes final quality audit."
- Operational Hazard: Converts a documentary credit into an uncollateralized consignment sale. Overseas port delays, customs strikes, or arbitrary warehouse rejections void the bank payment undertaking.
- Safe Replacement: Delete clause completely under UCP 600 Article 14(h).
4. Tight Presentation Window Traps
- Dangerous Clause in Field 48: "Documents must be presented to the bank within 7 calendar days after transport document on-board date."
- Operational Hazard: In Chattogram maritime logistics, shipping lines routinely take 7 to 10 days to release original Bills of Lading after container loading. A 7-day presentation window guarantees a late presentation discrepancy under UCP 600 Article 14(c).
- Safe Replacement: "Documents must be presented within 21 calendar days after shipment date but within credit validity."
5. Impossible Pre-Shipment Sample & Lab Test Traps
- Dangerous Clause in Field 47A: "Commercial Invoice must certify that pre-shipment bulk production sample was approved by buyer's head office in London prior to garment cutting."
- Operational Hazard: If buyer approval was given via informal email or verbal call without a formal stamped approval certificate, the negotiating bank will raise a discrepancy.
- Safe Replacement: "Commercial Invoice certifying that goods are manufactured in accordance with buyer purchase order specifications."
5. Master Soft Clause Remediation & MT707 Amendment Translation
| # | Clause Category | Dangerous L/C Wording | Risk Level Under UCP 600 | Required Formal SWIFT MT707 Amendment Request |
|---|---|---|---|---|
| 01 | Buyer Signature Veto | "Inspection certificate signed by buyer's designated QA manager Mr. John Doe." | CRITICAL (Buyer can veto payment) | AMEND FIELD 46A: Delete reference to John Doe. Insert: "Inspection Certificate issued by SGS Bangladesh or Intertek Bangladesh." |
| 02 | Post-Arrival Condition | "Payment conditional upon cargo clearance at Hamburg customs." | CRITICAL (Consignment risk) | AMEND FIELD 47A: Delete post-arrival condition in its entirety under UCP 600 Article 4 & 14(h). |
| 03 | FCR Release Hold | "FCR issued by forwarder only upon buyer email release." | CRITICAL (Cargo surrendered without payment) | AMEND FIELD 46A: Replace FCR with "Full set Clean On-Board Ocean Bills of Lading to Bank Order." |
| 04 | Tight Presentation | "Documents must be presented within 7 days of B/L date." | HIGH (Guaranteed late presentation) | AMEND FIELD 48: Extend presentation period to "21 days after shipment date." |
| 05 | Foreign Expiry | "Field 31D: Date and Place of Expiry: 30-NOV-2026 IN FRANCE." | CRITICAL (Courier transit expiry risk) | AMEND FIELD 31D: Amend place of expiry to "IN BANGLADESH AT NEGOTIATING BANK COUNTER." |
| 06 | Transshipment Prohibited | "Field 43T: Transshipment NOT ALLOWED." | HIGH (Feeder vessel B/L discrepancy) | AMEND FIELD 43T: Amend to "ALLOWED." |
| 07 | Carrier Freight Breakdown | "B/L must show detailed freight, bunker, and terminal breakdown." | MEDIUM (Shipping line refusal) | AMEND FIELD 47A: Delete breakdown requirement; state "B/L marked Freight Collect." |
| 08 | Arbitrary Deductions | "All discrepancies subject to $200 fee and 10% penalty." | MEDIUM (Unreasonable margin loss) | AMEND FIELD 47A: Align discrepancy fee to standard issuing bank schedule without arbitrary percentage penalties. |
6. Comprehensive Factory Case Studies
Case Study 1: The Trap of the Buyer QA Signature
- Factory: Dynamic Knitwear Ltd. (Tongi, Gazipur)
- Buyer: European Department Store Chain
- Order Value: $280,000 USD (30,000 Pcs Ladies Cardigans)
- L/C Condition: Field 46A demanded an "Inspection Certificate countersigned by Buyer Country QA Director Mr. Hans Richter whose signature is registered with the Issuing Bank."
- What Happened: Dynamic Knitwear finished production on time. However, Mr. Richter was transferred to another sourcing division in Vietnam and refused to visit Dhaka. The factory could not obtain the signature.
- Resolution: The Commercial Manager halted container stuffing and refused to release cargo to the forwarder. Dynamic Knitwear insisted on an urgent SWIFT MT707 amendment replacing the clause with an inspection certificate issued by Bureau Veritas Bangladesh. The amendment was received in 4 days, cargo was shipped, and full proceeds were realized without discrepancy.
Case Study 2: The Forwarder Cargo Receipt (FCR) Delivery Trap
- Factory: Sterling Denim Ltd. (Chattogram, Bangladesh)
- Buyer: Fast-Fashion Brand
- Order Value: $410,000 USD (50,000 Pcs Men's Denim Jeans)
- L/C Condition: Field 46A allowed a "Forwarder Cargo Receipt (FCR) issued by nominated forwarder XYZ Logistics Ltd."
- What Happened: Sterling Denim delivered 4 containers to the forwarder's depot in Chattogram. The buyer instructed the forwarder not to release the original FCR because European warehouse sales had slowed down. The forwarder held the FCR while the feeder vessel sailed.
- Resolution: Because Sterling Denim's commercial team had maintained strict delivery logs and filed a formal bonded customs export shipping bill, they issued a legal notice of cargo lien through their bank. To avoid international carrier liability, the buyer was forced to instruct the forwarder to release the FCR.
- Lesson Learned: Always require Master Ocean Bills of Lading or ensure FCRs are issued immediately upon depot gate-in without buyer intervention clauses.
Case Study 3: The 7-Day Presentation Window & Weekend Courier Trap
- Factory: Comfort Apparels Ltd. (Narayanganj, Bangladesh)
- Order Value: $175,000 USD
- L/C Condition: Field 48 specified "Documents must be presented within 7 days from shipment date."
- What Happened: Vessel sailed on a Thursday (B/L date: 15-Oct). The shipping line took until Tuesday (20-Oct) to issue the original Bill of Lading. Friday was a bank holiday in Bangladesh. Documents were presented on Sunday (25-Oct) — exactly 10 days after shipment.
- Outcome: The issuing bank rejected the presentation for Late Presentation Discrepancy under UCP 600 Article 14(c) and demanded a 10% price discount before releasing funds.
- Correction SOP: Commercial teams must never accept less than 15 to 21 days presentation validity in Field 48.
7. The 15-Point Commercial Executive Red Flag Checklist
8. 12 Critical Pitfalls in Clause Auditing
- Beginning Production on an Unamended Soft Clause: Trusting a buyer's verbal promise to fix a clause later.
- Overlooking Non-Documentary Conditions: Leaving ambiguous clauses in Field 47A that confuse negotiating banks.
- Accepting Consignee as Buyer on Ocean B/Ls: Losing cargo security by not consigning Bills of Lading to bank order.
- Accepting Tight Presentation Deadlines: Agreeing to 7-day presentation windows when B/Ls take 10 days to release.
- Neglecting Country of Expiry: Permitting L/Cs to expire in the issuing bank's foreign country.
- Overlooking Transshipment Prohibitions: Accepting
Field 43T: Prohibitedon Chattogram feeder routes. - Failing to Match Goods Descriptions Exactly: Adding minor descriptive words on invoices that do not appear in Field 45A.
- Accepting Subjective Quality Covenants: Allowing terms like "Subject to buyer store retail acceptance".
- Missing Specimen Signature Clauses: Discovering at bank presentation that an unobtainable signature specimen is demanded.
- Allowing Freight Breakdown Clauses on FOB Shipments: Carriers refusing to print detailed rate breakdowns on freight collect B/Ls.
- Failing to Audit Back-to-Back Linkages: Opening BTB L/Cs before Master L/C soft clauses are formally amended.
- Discarding Original Advising Schedules: Failing to maintain an authenticated archive of all MT707 amendments.
9. Important Commercial Terminology
- Soft Clause: A condition in an L/C that places payment realization under the unilateral veto or control of the buyer.
- Non-Documentary Condition: A term in an L/C that does not specify a corresponding document (governed by UCP 600 Art 14h).
- Forwarder Cargo Receipt (FCR): A non-negotiable receipt issued by a freight forwarder evidencing receipt of goods.
- Specimen Signature Card: An authenticated signature record held at a bank used to verify document signers.
- SWIFT MT707: The standardized interbank message format used to execute formal amendments to an existing MT700 L/C.
- Discrepancy Fee: An administrative bank fee deducted for non-compliant document presentations.
- Clean Bill of Lading: A transport document bearing no carrier notations of damaged packaging or defective goods.
- Consignment Sale: A transaction where payment occurs only after goods are sold at destination.
- Third-Party Inspection Agency: An independent global testing firm (SGS, Intertek, Bureau Veritas) inspecting goods.
- Beneficiary Certificate: A formal signed declaration by the exporter confirming compliance with specific operational terms.
- Port Demurrage Clause: A condition attempting to shift destination container detention costs onto the exporter.
- On-Board Notation: A dated carrier endorsement on a Bill of Lading certifying that cargo has been loaded on the vessel.
10. Interview Preparation Questions & Model Answers
Q1: What is a 'Soft Clause' and what is the primary danger it poses to an RMG exporter?
Model Answer: A soft clause is any condition in a Letter of Credit that makes bank payment realization contingent upon an event, document, or signature under the unilateral control of the buyer. The primary danger is that it destroys the independent payment guarantee of the bank, effectively converting the credit into an unsecured open account risk where the buyer can block payment at will.
Q2: How should a Commercial Executive handle an L/C requiring a buyer-signed inspection certificate?
Model Answer: The executive must immediately request a formal SWIFT MT707 amendment before cutting fabric or shipping cargo. The clause must be rewritten to specify an independent accredited third-party inspection agency (e.g., SGS, Intertek, or Bureau Veritas) or factory quality self-inspection, eliminating the buyer's unilateral signature veto.
Q3: What is the significance of UCP 600 Article 14(h) during an L/C clause audit?
Model Answer: Article 14(h) states that if a credit contains a condition without stating the specific document to be presented to prove compliance, banks will deem the condition as not stated and ignore it. During an audit, commercial executives should eliminate these non-documentary conditions to prevent operational confusion between the factory and the buyer.
Q4: Why must Field 43T (Transshipment) always state 'ALLOWED' for Bangladesh sea shipments?
Model Answer: Container vessels departing Chattogram Port are feeder vessels that must transfer containers to mother ocean vessels at regional hub ports like Singapore or Colombo. This transfer constitutes transshipment. If Field 43T states 'PROHIBITED', the Bill of Lading will contain an unavoidable fatal discrepancy.
TABLE 1: Master Soft Clause Audit & Neutralization Matrix
| Clause Category | Dangerous Soft Clause Wording | Severe Risk to Exporter | Recommended Safe MT707 Amendment |
|---|---|---|---|
| Buyer Signature Veto | Inspection certificate signed by buyer's representative whose signature must match issuing bank records. | Buyer can refuse to visit or sign, creating an incurable discrepancy and freezing bank payment. | Inspection certificate issued by SGS Bangladesh / Intertek Bangladesh or factory quality audit team. |
| Destination Arrival Condition | Payment released only after goods arrive at destination port and pass buyer warehouse QC. | Converts documentary L/C into consignment sale; goods can be rejected after arrival overseas. | Delete clause entirely. Payment available against standard on-board ocean Bills of Lading (UCP 600 Art 14h). |
| FCR Delivery Trap | Forwarder Cargo Receipt issued by buyer's forwarder only upon receipt of buyer written cargo release. | Buyer takes physical possession while instructing forwarder to withhold FCR from exporter. | Full set Clean On-Board Ocean Bills of Lading consigned to order of negotiating bank. |
| Test Report Trap | Fabric test report issued by buyer's domestic laboratory in Germany approving colorfastness. | Test report cannot be obtained before shipment; failure overseas voids payment. | Test report issued by accredited local laboratory (Bureau Veritas / SGS Dhaka) prior to ex-factory. |
| Tight Presentation Window | Documents must be presented within 7 calendar days after transport document date. | Ocean shipping lines in Chattogram take 8-10 days to release original B/Ls, causing late presentation. | Documents to be presented within 21 days after shipment date but within credit validity. |
| Vague Beneficiary Cert. | Beneficiary certificate certifying goods are produced under strict buyer ethical code of conduct. | Ambiguous criteria creates document examination disputes and arbitrary rejection. | Beneficiary certificate stating goods are manufactured in compliance with agreed PO specifications. |
| Post-Shipment Courier Trap | Original Courier Receipt showing 1 full set of non-negotiable docs dispatched to buyer within 24 hours of sailing. | Missing 24-hour deadline due to weekend/holiday creates fatal incurable discrepancy. | Beneficiary certificate certifying 1 copy of shipping docs was emailed to buyer within 3 working days. |
| Carrier Freight Breakdown | Ocean Bill of Lading must state freight charges broken down into ocean freight, BAF, CAF, and THC. | Shipping lines refuse detailed rate breakdowns on FOB Bills of Lading, causing carrier discrepancy. | Ocean Bills of Lading marked 'Freight Collect' (or 'Freight Prepaid' for CFR/CIF) without rate breakdown. |
TABLE 2: UCP 600 Articles Governing Clause Audits
| UCP 600 Article | Legal Principle | Commercial Application in Clause Auditing |
|---|---|---|
| Article 4 | Credits vs Contracts | A credit by its nature is separate from the sales contract; banks are not concerned with or bound by such contracts even if referenced in the credit. |
| Article 5 | Documents vs Goods/Services | Banks deal with documents and not with goods, services, or performance to which the documents relate. Destination quality claims cannot halt payment. |
| Article 14(a) | Standard of Examination | A nominated bank acting on its nomination must examine a presentation to determine, on the basis of the documents alone, whether they comply. |
| Article 14(c) | Presentation Period | If no presentation period is stated, banks will refuse documents presented later than 21 calendar days after shipment date. |
| Article 14(h) | Non-Documentary Conditions | If a credit contains a condition without stating the document to be presented in compliance, banks will deem such condition as not stated and ignore it. |
| Article 18(c) | Commercial Invoice Description | The description of the goods in a commercial invoice must correspond precisely with that in the credit (Field 45A). |
TABLE 3: Red Flag Risk Scoring for Master L/C Clauses
| Audit Dimension | Green Flag (Safe to Proceed) | Yellow Flag (Requires Merchandiser Check) | Red Flag (Halt Production / Demand MT707) |
|---|---|---|---|
| Inspection Terms | Third-party agency (SGS/Intertek) or factory self-inspection. | Buyer QA inspection with clear local contact details. | Buyer employee signature with signature specimen lodged at bank. |
| Transport Document | Master Ocean Bill of Lading to Bank Order. | Forwarder Cargo Receipt (FCR) from global freight forwarder. | FCR conditional on buyer overseas written clearance. |
| Presentation Period | 15 to 21 days after shipment date. | 10 to 14 days after shipment date. | Under 10 days (e.g., 5-7 days) after shipment date. |
| Payment Conditionality | Payment against compliant shipping documents. | Payment 60/90 days Usance with confirmed bank acceptance. | Payment conditional on destination port customs clearance or warehouse arrival. |
| Expiry Location | Field 31D expires in Bangladesh. | Field 31D expires at nominated bank counter in Dhaka. | Field 31D expires in Buyer's country (Europe / USA). |
Practical Commercial Flow
Real-world audit of a lethal buyer inspection clause and formulation of a compliant SWIFT MT707 amendment request.
Factory Real-Life Scenario
Scenario: A European buyer opened a $320,000 L/C with Field 47A stating: 'Payment will be released only after cargo arrives at Hamburg Port and passes destination customs clearance.'
Solution: The Commercial Manager immediately flagged this as an illegal non-documentary post-arrival soft clause violating UCP 600 Art 4 & 14(h), issued a hold notice to planning, and demanded an MT707 amendment deleting the clause.
Impact: The buyer amended the credit to standard FOB Chattogram terms; the factory avoided a potential total payment default when European port customs experienced general strikes 2 months later.
Commercial Officer Best Practice
Expert Commercial Audit SOP: When auditing Field 47A, always check for hidden financial traps such as 'All discrepancies subject to $150 USD deduction and buyer acceptance'. Replace with standard ICC banking practice or negotiate discrepancy fee waivers for minor clerical errors.
Top Beginner Mistakes to Avoid
- Accepting clauses that make bank payment conditional upon buyer warehouse arrival or retail point-of-sale approval.
- Agreeing to inspection certificates requiring buyer employee signatures without specifying an alternative third-party inspection agency.
- Allowing Forwarder Cargo Receipts (FCR) where the forwarder is prohibited from releasing the FCR without buyer written authorization.
- Overlooking tight 7-day presentation periods when gathering original ocean Bills of Lading takes 10 to 12 days.
- Cutting fabric or shipping cargo on verbal buyer promises to amend soft clauses later.
Important Commercial & Trade Terminology (12 Terms)
A conditional clause inserted into a Letter of Credit that makes the bank payment undertaking dependent upon an event, document, or approval under the unilateral control of the buyer.
💡 Note: Completely nullifies the independent guarantee of the bank and turns the L/C into an open account risk.A condition stated in an L/C that does not specify a corresponding document to evidence compliance (governed by UCP 600 Article 14h).
💡 Note: While banks disregard these conditions during examination, commercial teams should eliminate them to avoid legal disputes.A receipt issued by a freight forwarder confirming that cargo has been received for shipment, but which is not a negotiable document of title like an Ocean Bill of Lading.
💡 Note: If an L/C requires an FCR, ensure the forwarder cannot withhold it under buyer instructions.A requirement in Field 46A/47A demanding that a document be signed by an individual whose signature must match a specimen card kept in the issuing bank's records.
💡 Note: A fatal soft clause because the exporter has no access to the bank's specimen signature card to verify compliance.The standardized electronic interbank message format used to issue formal amendments, extensions, or corrections to an existing MT700 Letter of Credit.
💡 Note: No verbal or email promise from a buyer is legally valid until an authenticated MT707 is advised by your bank.A bank charge (typically $75 to $150 USD) deducted by the issuing bank for each non-compliant presentation of documents under UCP 600 Article 16.
💡 Note: Audit Field 47A to ensure excessive arbitrary discrepancy deduction clauses are eliminated.A Bill of Lading or transport document that bears no clause or notation expressly declaring a defective condition of the goods or packaging (UCP 600 Article 27).
💡 Note: Ensure carrier does not stamp 'cartons crushed' or 'wet packaging' on the B/L.A trading arrangement where the exporter retains ownership of goods until they are sold by the buyer at destination; soft clauses often disguise consignment terms.
💡 Note: Never allow L/C clauses that defer payment until retail sale or warehouse clearance.An independent international testing and inspection organization (e.g., SGS, Intertek, Bureau Veritas, TÜV SÜD) nominated to verify cargo quantity and quality.
💡 Note: The gold standard replacement for subjective buyer inspection clauses.A formal declaration on factory letterhead signed by the exporter certifying compliance with specific operational conditions (e.g., courier dispatch, shipment notices).
💡 Note: Must precisely replicate the wording demanded in Field 46A/47A.A condition attempting to hold the exporter financially liable for container detention or port storage fees incurred at destination port.
💡 Note: Unacceptable under FOB or CFR sales terms; must be deleted via MT707.A dated notation on an ocean Bill of Lading signed or initialed by the carrier confirming that goods have been physically loaded onto the named vessel.
💡 Note: The on-board notation date represents the official Date of Shipment under UCP 600.Interview Preparation Questions & Answers (12 Questions)
Master these high-frequency interview questions for Commercial Officer, Merchandising, and Export Executive roles.
A soft clause is any condition in an L/C that places payment realization under the unilateral control or veto of the buyer or issuing bank (e.g., requiring an inspection certificate signed by a buyer's representative whose signature must match bank specimen records). It is dangerous because it destroys the independent payment guarantee of the L/C, allowing the buyer to block payment at will, effectively converting the transaction into an uncollateralized open account risk.
Frequently Asked Questions (10 FAQs)
Clear, beginner-friendly answers to the most common questions about the Commercial Department.
Key Takeaways & Summary Points
Executive Lesson Summary
Rigorous L/C clause auditing neutralizes commercial traps, eliminates unilateral buyer veto powers, and ensures that export payment realization remains 100% within the documentary control of the garment factory.
Lesson Downloads & SOP Templates
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Read GuideHS 6109.10.00
T-shirts, singlets and other vests, knitted or crocheted, of cotton
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