The tariff classification of a trunk organizer with an insulated cooler bag from China

N345445 February 26, 2025 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.92.9700; 9903.88.03; 9903.01.20 Derick Mullikin Sheltered International 1 South 3rd StreetFernandina Beach, FL 32034 RE:  The tariff classification of a trunk organizer with an insulated cooler bag from China Dear Mr. Mullikin: In your letter dated January 28, 2025, you requested a tariff classification ruling on behalf of your client, Natural Life Collections Inc. You have submitted photographs and descriptive literature for our review. The article consists of a trunk organizer and a removable insulated cooler bag. It is designed to provide storage, protection, organization, and portability to items such as books, toys, water bottles, auto accessories, or other personal effects. In your correspondence, you stated that the organizer is composed of Recycled Polyethylene Terephthalate (RPET) in the form of textile with an outer surface of plastic sheeting. It is designed to be used in the trunk of an automobile. The organizer is a square shaped. It is divided into three equal sections with two handles. The article measures approximately 23 inches (L) by 14 inches (W) by 12 inches (H). In your request, you suggest the article be classified under subheading 4202.92.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for insulated food and beverage bags, with outer surface of sheeting of plastic or of textile materials, other. The organizer and the removable insulated cooler bags are considered as composite goods in accordance with General Rule of Interpretation 3(b) of the HTSUS. The essential character is imparted by the trunk organizer as that is the principal component which predominates in weight, bulk, and use. Moreover, the trunk organizer is the component that is most likely to prompt the consumer to purchase the article. The insulated cooler bag is optional component that will be used as needed. The applicable subheading for the trunk organizer with the insulated cooler bag will be 4202.92.9700, HTSUS, which provides for other containers and cases, with outer surface of sheeting of plastic or of textile material, other, other, other, and other.  The general rate of duty will be 17.6 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4202.92.9700, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 4202.92.9700, HTSUS, listed above. Effective February 4, 2025, in accordance with the President’s Executive Order “Imposing Duties to Address the Synthetic Opioid Supply Chain in the People’s Republic of China,” all products of China and Hong Kong as provided by heading 9903.01.20 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(s), HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.20, in addition to subheading 4202.92.9700, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Vikki Lazaro at vikki.lazaro@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division