The tariff classification of a women’s belt from China

N291317 November 8, 2017 CLA-2-62:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 6217.10.9510 Ms. Elise Shibles Sandler, Travis & Rosenberg, P.A. 505 Sansome Street, Suite 1475 San Francisco, CA 94111 RE: The tariff classification of a women’s belt from China Dear Ms. Shibles, In your letter dated October 11, 2017, on behalf of your client, VF Jeanswear Limited Partnership, you requested a tariff classification ruling. The submitted sample, Style RM29, is a women’s belt. The belt is approximately 40 inches in length and ¾ inches in width and features an outer textile layer composed of 100% cotton woven fabric and an inner layer of 100% plastic. The belt fastens with a metal buckle. Style RM29 is constructed of multiple components that are prima facie classifiable in different headings, i.e., cotton woven fabric, PVC and metal. As such, it is a composite good whose classification is governed by General Rule of Interpretation (GRI) 3(b). GRI 3(b) of the HTSUS states as follows: (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. GRI 3(b) requires that the article be classified by reference to its essential character. Customs and Border Protection has (CBP) previously ruled that the essential character is determined by the component that girds the waist. Each of the belt’s component is of equal weight. In terms of bulk, the woven fabric surpasses the insubstantial plastic component. Consequently, the woven fabic girds the waist and thus constitutes the essential character of the belt. The applicable subheading for Style RM29 will be 6217.10.9510, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Other made up clothing accessories…Accessories: Other: Other, Of cotton." The duty rate will be 14.7% 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 Rosemarie Hayward via email at rosemariecasey.hayward@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division