Ms. Una Gauthier
Barthco International, Inc.
One CVS Drive
Woonsocket, RI 02895

RE: The tariff classification of insulated cooler bag from China

Dear Ms. Gauthier:

In your letter dated December 11, 2008, on behalf of CVS Pharmacy, you requested a classification ruling. The sample which you submitted is being retained by this office.

Item 335135 is a soft-sided insulated cooler bag. The outer surface of the bag is composed of two materials. The front panel of the bag and the top are composed of man-made textile material. The sides, back and bottom are composed of plastic sheeting material. The essential character of the cooler bag is imparted by the textile fabric of the front panel. The bag is designed to provide storage, protection, portability, and organization to food and beverages during travel. It is also capable of maintaining the temperature of food and beverages. It features a rubberized grip handle, adjustable shoulder strap, two storage compartments, a plastic interior lining, and a zippered closure. There is a layer of foam between the lining and the outer surface materials.

The applicable subheading for item 335135 will be 4202.92.0807, Harmonized Tariff Schedule of the United States (HTSUS), which provides for insulated food or beverage bags, with outer surface of man-made textile material. The duty rate will be 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

HTSUS 4202.92.0807 falls within textile category 670. With the exception of certain products of China, quota/visa requirements are no longer applicable for merchandise which is the product of World Trade Organization (WTO) member countries. Quota and visa requirements are the result of international agreements that are subject to frequent renegotiations and changes. To obtain the most current information on quota and visa requirements applicable to this merchandise, we suggest you check, close to the time of shipment, the “Textile Status Report for Absolute Quotas” which is available on our web site at For current information regarding possible textile safeguard actions on goods from China and related issues, we refer you to the web site of the Office of Textiles and Apparel of the Department of Commerce at

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 Vikki Lazaro at (646) 733-3041.


Robert B. Swierupski
National Commodity Specialist Division