The tariff classification of a handbag and interchangeable covers from China

N100807 April 30, 2010 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.22.4500, 6307.90.9889, 3926.90.9980 Cortney O’Toole Morgan Barnes Richardson 11 Dupont Circle, NW Washington, DC 20036 RE: The tariff classification of a handbag and interchangeable covers from China Dear Ms. Morgan: In your letter dated April 1, 2010, you requested a tariff classification ruling on behalf of your client Miche Bag, LLC. Your samples will be returned to you. You have requested a binding ruling on a handbag, referred to as the “Classic Base Bag,” that may be used with interchangeable covers that change the look of the bag. In your letter, you state the covers are intended solely for use as interchangeable, decorative covers to the “Classic Base Bag” and not intended to be used on their own. You also stated that the handbag and individual covers will be imported separately. The bag that you refer to as the “Classic Base Bag” is a handbag constructed with an outer surface of 100% cotton textile material. It is designed and sized to contain the small personal effects that would normally be carried on a daily basis. The bag has a textile-lined storage compartment with a zippered pocket and two open pockets on the sidewalls. The bag has a nylon zipper closure and two polyvinyl chloride (PVC) carrying handles. It measures approximately 11” (W) x 7” (H) x 4” (D). The styles that you refer to as “Joie” and “Ashley” are decorative covers constructed of 100% cotton textile fabric. The covers fit over the exterior of the “Classic Base Bag” and attach by means of hidden magnets. They each measure approximately 11” (W) x 7” (H) x 4” (D). The styles that you referred to as “Zoe” and “Belle” are decorative covers that are constructed of cellular plastic sheeting backed with uniformly dyed plain textile fabric reinforcement. The covers attaches to the exterior of the “Classic Base Bag” by means of hidden magnets. They each measure approximately 11” (W) x 7” (H) x 4” (D). The applicable subheading for the “Classic Base Bag” will be 4202.22.4500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of textile materials, of vegetable fibers and not of pile or tufted construction, of cotton. The duty rate will be 6.3 percent ad valorem. The applicable subheading for covers “Joie” and “Ashley,” imported separately from the base handbag, will be 6307.90.9889, HTSUS, which provides for other made up textile articles, other. The rate of duty will be 7% ad valorem. The applicable subheading for covers “Zoe” and “Belle,” imported separately from the base handbag, will be 3926.90.9980, HTSUS, which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Vikki Lazaro at (646) 733-3041. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division