CLA-2-42:S:N:N3G:341 860908

Mr. Louis S. Shoichet
Siegel, Mandell & Davidson, P.C.
One Whitehall Street
New York, NY 10004

RE: The tariff classification of a earring closet from China.

Dear Mr. Shoichet:

In your letter dated February 27, 1991, on behalf of Avon Products, Inc., you requested a tariff classification ruling. The submitted sample is described as item #PP 93418, "Earring Closet". The article contains 24 pockets (12 pockets on each side when folded at the center). The item is intended to contain jewelry or other personal items. The overall length is 26 inches, and it is 13 inches wide. When folded over a clothes hanger the length is 13 inches. The item has four sets of snap fasteners which serve to secure the item both when hanging on a hanger, and when in a rolled/folded condition. The samples submitted are manufactured of a PVC outer material, with clear PVC sheeting over either a PVC material or a 65% polyester/35% cotton fabric material. In either event, the outer surface is the PVC sheeting material. When in a rolled condition the jewelry is secured within the roll. The item can be placed in a closet both at home and when traveling. Your sample is being returned per your request.

In your letter dated February 27, 1991, you have indicated that all available literature has been submitted. We assume that your client Avon Products, Inc., does not possess a "Product Marketing Profile" nor a "Vendors Specification Sheet" as in prior instances.

The applicable subheading for item #PP 93418, the earring closet of plastic sheeting, will be 4202.92.4500, Harmonized Tariff Schedule of the United States (HTS), which provides for travel, sports and similar bags, with outer surface of plastic sheeting, other, other. The duty rate will be 20 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport