CLA-2:CO:R:C:G 082265 SR

Ms. Ginni Brown
Apple Marketing, Inc.
520 Weadley Road
King of Prussia, Pa. 19406

RE: Classification of a ski wallet

Dear Ms. Brown:

This is in reference to your letter dated March 25, 1988, requesting the tariff classification of a ski wallet under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). A sample was submitted.

FACTS:

The merchandise at issue is a nylon ski wallet. It is rectangular in shape and measures 4 inches by 4.75 inches. It has one plastic zipper across the top that opens up to a pocket which is the length of the item. There is another zipper half way down which opens up to a separate smaller pocket. There is a textile braided neck strap that measures nearly 38.75 inches. This wallet is to be worn around the neck while skiing to hold such items as keys and money.

ISSUE:

What is the tariff classification of the ski wallet?

LAW AND ANALYSIS:

Subheading 4202.32.9550, HTSUSA, provides for trunks, suitcases, sports bags, of textile materials, articles of a kind normally carried in the pocket or in the handbag, with outer surface of textile materials.

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The ski wallet at issue is not meant to be carried in the pocket or handbag, it is intended to be worn around the neck while skiing. It is, however, an article of a kind that would normally be carried in a pocket or purse. When dressed for skiing, pockets are often inaccessible or if accessible a skier does not want bulky items, such as keys, in them in case he should fall. The merchandise at issue is a wallet that is worn hung around the neck under the ski suit for the convenience of the skier.

HOLDING:

The ski wallet at issue is classifiable under subheading 4202.32.9550, HTSUSA, which provides for trunks, suitcases, sports bags, of textile materials, articles of a kind normally carried in the pocket or in the handbag, with outer surface of textile materials, other, other, of man-made fibers. The rate of duty is 20 percent ad valorem and the textile category number is 670. As a product of China, this merchandise is currently subject to both quota and export license restraints based upon international textile trade agreements.

Due to the changeable nature of the statistical annotation(the ninth and tenth digits of the classification) and the restraint (quota/visa) categories, you should contact your local Customs office prior to importation of this merchandise to determine the current status of any import restraints or requirements.

Sincerely,

John Durant, Director
Commercial Rulings Division

6cc: AD NY Seaport
SRosenow: fnl/gc/3/7/89