Ms. Sandy Pray
Camuto Group
dba VCS Group, LLC
100 Highland Drive
Westampton, NJ 08060

RE: The tariff classification of a tote bag and key ring from China

Dear Ms. Pray:

In your letter dated March 3, 2017, you requested a tariff classification ruling. The ruling is requested on a tote bag and accompanying key ring. You have submitted a sample which will be returned to you, per your request.

The submitted sample is a women’s tote bag, style LK-ISABEL-TO. It is designed and sized to contain personal effects during travel, measuring approximately 15” wide x 13” high x 4 ½” deep. The tote bag is constructed of polyurethane plastic strips which have been interwoven to create the entire outer surface of the bag. Each strip measures approximately 5mm to 6mm in width. The tote features an open top and two braided shoulder straps. The interior has one main storage compartment that is unlined. Closed around one strap is a key ring made up of a zinc alloy jump ring which opens to allow keys to be attached. From the jump ring extends a decorative piece of leather. The key ring can be detached from the handbag and used separately.

The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of products or articles put together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).” Sets are classified according to the component, or components taken together, which can be regarded as conferring on the set as a whole its essential character.

The tote bag and key ring, as imported, do not meet this definition of a set. The goods will be classified separately.

The interwoven strips of plastic that compose the tote bag’s outer surface are considered "plaiting materials" as described in Chapter Note 1 of Chapter 46, HTSUS, which states as follows: In this chapter the expression "plaiting materials" means materials in a state or form suitable for plaiting, interlacing or similar processes; it includes straw, osier or willow, bamboos, rattans, rushes, reeds, strips of wood, strips of other vegetable material (for example, strips of bark, narrow leaves and raffia or other strips obtained from broad leaves), unspun natural textile fibers, monofilament and strip and the like of plastics and strips of paper, but not strips of leather or composition leather or of felt or nonwovens, human hair, horsehair, textile rovings or yarns, or monofilament and strip and the like of chapter 54.

The applicable subheading for the tote bag will be 4602.90.0000, HTSUS, which provides for Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from the articles of heading 4601: Other. The rate of duty will be 3.5% ad valorem.

The applicable subheading for the key ring made of zinc alloy will be 7907.00.6000, HTSUS, which provides for other articles of zinc, other.  The rate of duty will be 3% 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 the World Wide Web 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 Charlene Miller at [email protected].


Steven A. Mack
National Commodity Specialist Division