The tariff classification of a diaper changing bag from China

N288614 August 15, 2017 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.92.4500 Ms. Michelle L. Cuevas-Castillo Ethikos Market 5513 Eric Street Allendale, MI 49401 RE: The tariff classification of a diaper changing bag from China Dear Ms. Cuevas-Castillo: In your letter received in our office July 27, 2017, you requested a tariff classification ruling. You have submitted a sample, which is being returned to you under separate cover. Item number AB/UC-BG/01 is a diaper bag with a changing mat. The diaper bag is constructed with an outer surface of polyurethane (PU) plastic sheeting. It is designed to provide storage, protection, portability, and organization to personal effects and accessories such as clothing, diapers, bottles, or other sundry articles. The interior has a textile lining with an open storage compartment, one zipperred wall pocket, two padded pockets and three elasticized pockets. The storage compartment secures with a zipper closure. The front exterior has a zippered pocket along the entire width of the bag where the changing mat is stored. There are two small zipper pockets on the exterior front and back panels. The bag has an adjustable, removable shoulder strap, two carry handles and two clip attachments on each side which are used to facilitate hanging the bag from a stroller. It measures approximately 17 ½” (W) x 12” (H) x 6” (D). The changing mat is covered with Thermoplastic Polyurethane (TPU) on one side and polyester textile material on the other. It measures approximately 28” (L) X 18” (H) and when folded, measures approximately 10” (W) x 7” (H). It features an exterior pocket, a carrying strap and secures with a hook and loop closure. In a conversation with our office, you stated the diaper bag and changing mat are marketed and sold together. The diaper bag and changing mat are considered to be a set, General Rule of Interpretation 3(b), noted. The essential character of the set is imparted by the diaper bag. In your letter, you suggest classification of the bag under subheading 4202.22.1500, Harmonized Tariff Schedule of the United States, (HTSUS), which provides in part, for handbags, whether or not with shoulder strap, including those without handle, with outer surface of sheeting of plastic. Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRI). Pursuant to GRI 1, goods shall be determined according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes under the heading that most specifically describes them. The diaper bag is designed and sized to contain larger personal effects that would normally be carried in a travel bag such as clothing, books, sundry articles or food. Thus, the diaper bag is more appropriately classified in the subheading that provides for travel, sports, and similar bags. The applicable subheading for the diaper changing bag will be 4202.92.4500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for travel, sports, and similar bags, with outer surface of sheeting of plastic, 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 https://hts.usitc.gov/current. 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, Steven A. Mack Director National Commodity Specialist Division