The tariff classification of handbags and tote bags from China

N216805 June 6, 2012 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.22.1500, 4202.22.4500, 4202.92.1500, 4202.92.4500 Amy Hess World Exchange, Inc. 8840 Bellanca Avenue Los Angeles, CA 90045 RE: The tariff classification of handbags and tote bags from China Dear Ms. Hess: In your letter dated April 30, 2012, you requested a tariff classification ruling on behalf of your client, Amy Kathryn Design, LLC. Your samples will be returned to you. Style 4714G is a handbag constructed with a body of cotton textile material and polyurethane (PU) trim. You state in your letter that the outer surface of the bag is 40% PU and 60% textile. As such, the essential character of the bag is imparted by the cotton material, General Rule of Interpretation 3(b) noted. The bag is designed and sized to contain the small personal effects that would normally be carried on a daily basis. It has a textile-lined storage compartment with an open pocket and a zippered pocket on the side walls. The bag has a metal zipper closure at the top, two PU carrying handles, and an adjustable, removable webbed shoulder strap. The front exterior has two patch pockets with flaps that secure with magnetic closures. It measures approximately 12” (W) x 10” (H) x 5” (D). Style 4736A is a handbag constructed of both cotton textile material and PU plastic sheeting. The front exterior of the bag is made of PU plastic and has a double flap of cotton which secures by means of a hidden magnetic closure. The bottom, side panels, shoulder strap and a portion of the back exterior are made of PU plastic. The back exterior has an 8” x 6.5” panel of cotton textile. You state in your letter that the outer surface of the bag is 60% PU and 40% textile. As such, the essential character is imparted by the PU plastic sheeting, GRI 3(b) noted. The bag is designed and sized to contain the small personal effects that would normally be carried on a daily basis. It has a textile-lined storage compartment with three open pockets and a zippered pocket on the side walls. The bag measures approximately 9.5” (W) x 9.5” (H) x 3.5” (D). Style 4005H is a tote bag constructed of both cotton textile material and PU plastic sheeting. The front and back exteriors of the bag are made of cotton material. The two patch pockets on the front exterior, the side panels, bottom, handles, and shoulder strap are made of PU plastic. While you state in your letter that the PU slightly predominates in the overall surface area of the bag, our examination of the bag indicates that, for this style, the textile provides the more striking visual impact. As such, the essential character is imparted by the cotton, GRI 3(b) noted. The tote bag is designed and sized to provide storage, protection, portability, and organization to books, food, articles of clothing, and other larger personal effects commonly associated with travel. It has a textile-lined storage compartment with three open pockets, a zippered pocket, a three slot pen pocket and two open mesh pockets on the side walls. The back exterior has a zippered pocket. The bag secures with a nylon zipper closure and measures approximately 15” (W) across the middle x 10.5” (H) x 7.25” (D). Style 4732B is a tote bag constructed of both cotton textile material and PU plastic sheeting. The front panel of the bag is made of cotton that has the PU overlay that covers approximately 50% of the front panel. The front panel is also bordered by PU trim. The bottom, side panels, shoulder strap and back exterior are made of PU plastic. You state in your letter that the outer surface if 60% PU and 40% textile. As such, the essential character is imparted by the PU plastic sheeting. The tote bag is designed and sized to provide storage, protection, portability, and organization to books, food, articles of clothing, and other larger personal effects commonly associated with travel. It has a textile-lined storage compartment with two open pockets and a zippered pocket on the side walls. The bag has a zippered pocket on the back exterior and measures approximately 16” (W) x 13” (H) x 2.5” (D). Style 4363 is a tote bag with a detachable pouch constructed of cotton textile material. The tote bag and pouch are considered a set for tariff purposes with the tote bag imparting the essential character. The tote bag is designed and sized to provide storage, protection, portability, and organization to books, food, articles of clothing, and other larger personal effects commonly associated with travel. It has a textile-lined storage compartment with two open pockets and a zippered pocket on the side walls. The bag has a nylon zipper closure at the top, a single shoulder strap and measures approximately 24” (W) x 12.5” (H) x 9.5” (D). The applicable subheading for style 4714G 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 rate of duty will be 6.3 percent ad valorem. The applicable subheading for style 4736A will be 4202.22.1500, 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. The applicable subheading for style 4005H and 4363 will be 4202.92.1500, HTSUS, which provides for travel, sports and similar bags, with outer surface of textile materials, of vegetable fibers and not of pile or tufted construction, of cotton. The rate of duty will be 6.3 percent ad valorem. The applicable subheading for style 4732B will be 4202.92.4500, HTSUS, which provides for travel, sports and similar bags, with outer surface of plastic sheeting or of textile materials, other. The rate of duty will be 20 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