The tariff classification of a handbag from China or Vietnam

N255525 August 15, 2014 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.21.6000; 4202.21.9000 Jason Nichols Coach Services, Inc. One Coach Way Jacksonville, FL 32218 RE: The tariff classification of a handbag from China or Vietnam Dear Mr. Nichols: In your letter dated July 11, 2014, you requested a tariff classification ruling. You have submitted one sample, which is being returned to you. Style MC32401P is a compartmentalized handbag constructed of genuine leather. The handbag is slightly triangular is shape. It designed and sized to contain the small personal effects that would normally be carried on a daily basis. It features two short shoulder straps. The interior of the handbag is divided into three small compartments. The center compartment has a 10” opening that is secured with a zipper. The two outer compartments have opening that measure approximately 11” when stretched to their maximum length. When the bag is in use and being carried by the straps, these openings are significantly smaller. The three compartments together are secured by means of a 2” wide strap that is affixed to the back panel of the bag. It goes over the top opening of the bag to secure at the front of the bag. The outer dimensions of the handbag measure approximately 12” (W) x 11” (H) x 4” (W). In your ruling request you suggested that style MC32401P is classified under subheading 4202.91.00, which provides for other cases and containers, with outer surface of leather. The submitted sample is a handbag. Handbags are specifically provided for elsewhere in the heading and shall be classified therein. While you have not specifically suggested the classification for travel, sports, and similar bags, you have mentioned in your letter that you believe this style shall be correctly classified as a tote bag. However, the shape, dimensions, interior storage capacity, and design features of this bag, in particular the compartmentalization, indicate that it is not suitable for use as travel bag or tote bag. Please see New York Ruling N254811, dated July 24, 2014 and N247894, dated November 21, 2013. The applicable subheading for style MC32401P, if valued not over $20, will be 4202.21.6000, 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 leather, of composition leather or of patent leather, other, valued not over $20 each. The rate of duty will be 10% ad valorem. The applicable subheading for style MC32401P, if valued over $20, will be 4202.21.9000, HTSUS, which provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of leather, of composition leather or of patent leather, other, valued over $20 each. The rate of duty will be 9% 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 vikki.lazaro@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division