CLA-2 CO:R:C:T 950000 KWM
Mr. Felipe Angel
   AG Brokerage
   9320 Bellanca Avenue
   Los Angeles, California  90045
   RE:  Fendi drawstring pouches; Jewelry pouches; Similar
        containers; Travel, sports and similar bags; Suitable for
        long term use; Textile.
   Dear Mr. Angel:
        This is in response to your letter of July 2, 1991,
   regarding the tariff classification of merchandise described
   as "jewelry pouches."  Our reply follows.
   FACTS:
        Your letter describes the merchandise as jewelry pouches.
   Three items are at issue, differing primarily in size.  They
   are textile bags, closed by means of a drawstring at the top.
   Each is black and has a gold lining.  The largest bag is
   embroidered on the bottom with the Fendi logo.  The lining of
   each bag also displays the Fendi logo.  The largest bag
   measures approximately 8 1/2 inches by 7 inches; the medium
   bag 5 1/2 inches by 5 inches; the smallest bag 4 1/2 inches by
   4 inches.  Your correspondence also included information from
   Ben-K America Co., Ltd., the manufacturer of the bags.  That
   information indicates that the bags are mad from two layers of
   textile: the exterior or "body" of the bags, and a "lining."
   The body of the bag is made from nylon fabric and nylon
   flocking.  The lining is nylon acetate fabric.  The bag also
   has de minimus amounts of string cord and metallic trim.
   Lastly, Ben-K asserts that the merchandise will be principally
   used "for jewelry holder and . . . will be given away for
   advertising."
   ISSUE:
        How are these bags classified under the Harmonized Tariff
   Schedule of the United States Annotated?
LAW AND ANALYSIS:
        Classification under the Harmonized Tariff Schedule of
   the United States Annotated (HTSUSA) is made in accordance
   with the General Rules of Interpretation (GRI's).  The
   systematic detail of the harmonized system is such that
   virtually all goods are classified by application of GRI 1,
   that is, according to the terms of the headings of the tariff
   schedule and any relevant Section or Chapter Notes.
        Heading 4202, HTSUSA, provides for:
        4202      Trunks, suitcases, vanity cases, attache cases.
                  briefcases, school satchels, spectacle cases,
                  binocular cases, camera cases, musical
                  instrument cases, gun cases, holsters and
                  similar containers; toiletry bags, knapsacks,
                  purses, map cases, cigarette cases, tobacco
                  pouches, toolbags, sports bags, bottle cases,
                  jewelry boxes, powder case, cutlery cases and
                  similar containers, of leather or of
                  composition leather, of plastic sheeting, of
                  textile materials, of vulcanized fiber or
                  paperboard, or wholly or mainly covered with
                  such materials.
   Customs regularly consults the Explanatory Notes to the
   HTSUSA, which constitute the official interpretation of the
   tariff at the international level.  The Explanatory Notes
   indicate that heading 4202, HTSUSA, properly includes "similar
   containers" such as pen-cases, tobacco pouches, tool and
   jewelry rolls; in other words, articles which are ejusdem
   generis to the named articles.  Such articles are
   characterized by their design or fit for storing, protecting
   or transporting other goods.  Based on the assertions of your
   July 2, 1991, submission, and extensive experience with
   products of this type, our New York office advises us that the
   instant articles are designed to hold, store or protect
   jewelry or other personal effects;  that the small and medium
   bag are of the type normally carried on the pocket or handbag,
   and the larger suitable for personal items during travel.
   Lastly, note that the sample articles are constructed from a
   quality textile material, are well made, and appear suitable
   for such uses.
   HOLDING:
        The jewelry pouches are classified as follows.
        The small and medium sized pouches (4 1/2 inches by 4
   inches, and 5 1/2/ inches by 5 inches) are classified in
   subheading 4202.32.9550, HTSUSA.  The applicable rate of duty
   is 20 percent ad valorem.  The applicable textile visa
   category is 670.
        The large pouch is classified in subheading 4202.92.3030,
   HTSUSA.  The applicable rate of duty is 20 percent ad valorem.
   The applicable textile visa category is 670.
        The designated textile and apparel category may be
   subdivided into parts.  If so, the visa and quota category
   requirements applicable to the subject merchandise may be
   affected.  Since part categories are the result of
   international bilateral agreements which are subject to
   frequent renegotiations and changes, to obtain the most
   current information available, we suggest you check, close to
   the time of shipment, the Status Report on Current Import
   Quotas (Restraint Levels), an issuance of the U.S. Customs
   Service, which is updated weekly and is available at your
   local Customs office.
        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 the importation of this
   merchandise to determine the current status of any import
   restraints or requirements.
Sincerely,
                                      John A. Durant, Director
                                      Commercial Rulings Division