The tariff classification of handbags from China

N206818 March 30, 2012 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.22.1500 Belinda Lopez Phillips Van Heusen Corporation 200 Madison Avenue New York, NY 10016 RE: The tariff classification of handbags from China Dear Ms. Lopez: In your letter dated February 22, 2012, you requested a tariff classification ruling. Your samples will be returned to you. Your samples are four handbags identified as styles 1452, 1453, 1096 and 1097. They are all constructed with an outer surface of more than one material. The classification of goods consisting of more than one material or substance shall be classified according to the principles of the General Rules of Interpretation (GRI’s). For these styles, they will be classified according to GRI 3(b) which states, in part, that: ...composite goods...made up of different components...which cannot be classified by reference to GRI 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. Style 1097 is a handbag constructed with a body of polyurethane (PU) plastic sheeting and a flap of calf hair. The outer surface area composed of polyurethane is greater than that of the calf hair. Additionally, the information you provided indicates that the value of the calf hair makes up only approximately 15% of the overall value. As such, the essential character is imparted by the polyurethane plastic sheeting. The bag is designed to contain the personal effects that would normally be carried on a daily basis. The interior compartment is textile-lined and has a zippered pocket with an overlapping open pocket on the backwall. The bag has a flap that secures with a magnetic closure, a wrist strap for carrying and a metal zipper along the perimeter of the bag for aesthetics purposes only. It measures approximately 7.5” (W) x 5.5” (H) x 1.5” (D). Style 1096 is a handbag constructed with an outer surface of both polyurethane (PU) plastic sheeting and leather with calf hair. The front panel is composed of calf hair leather bordered by polyurethane. The back panel, bottom panel, carrying handles, shoulder strap, sides and top portion of the bag is composed of polyurethane. The outer surface area covered by polyurethane is greater than that of the leather. The information you provided indicates that the calf hair makes up less than 25% of the overall value of the bag. As such, the essential character is imparted by the polyurethane plastic sheeting. The bag is designed to contain the personal effects that would normally be carried on a daily basis. The interior compartment is textile-lined and has a zippered pocket with an overlapping open pocket on the backwall. The bag has a strap that extends over the top of the bag with both a magnetic and metal zipper closure. Both the front and back exterior have an open pocket across the entire width of the bag. It measures approximately 11” (W) x 9” (H) x 6” (D). Style 1452 is a handbag constructed with an outer surface of both polyurethane (PU) plastic sheeting and linen textile material. The front and back panels are composed of linen textile bordered by polyurethane. The bottom panel, carrying handles, shoulder strap, sides and top portion of the bag are composed of polyurethane. Based on the information you provided, the polyurethane is the more costly material and provides the greater value to the bag. As such, the essential character is imparted by the polyurethane plastic sheeting. The bag is designed to contain the personal effects that would normally be carried on a daily basis. The interior compartment is textile-lined and has a zippered pocket with an overlapping open pocket on the backwall. The bag has a strap that extends over the top of the bag with both a magnetic and metal zipper closure. Both the front and back exterior have an open pocket across the entire width of the bag. It measures approximately 11” (W) x 9” (H) x 6” (D). Style 1453 is a handbag constructed with an outer surface of both polyurethane (PU) plastic sheeting and linen textile material. The front panel is composed of linen textile material while the sides, flap and rear exterior are composed of polyurethane plastic sheeting. Based on the information you provided, the polyurethane is the more costly material and provides the greater value to the bag. As such, the essential character is imparted by the polyurethane plastic sheeting. The bag is designed to contain the personal effects that would normally be carried on a daily basis. The interior is textile-lined and has a zippered pocket with an overlapping open pocket on the backwall. The bag has a flap that secures with a magnetic closure, a wrist strap for carrying and a metal zipper along the perimeter of the bag for aesthetic purposes only. It measures approximately 7.5” (W) x 5.5” (H) x 1.5” (D). The applicable subheading for all styles will be 4202.22.1500, 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 sheeting of plastic. The rate of duty will be 16 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, Thomas J. Russo Director National Commodity Specialist Division