CLA-2-42:OT:RR:NC:N4:441
Ms. Sandy Pray
Camuto Group, Inc.
dba VCS Group, LLC
100 Highland Drive
Westampton, NJ 08060
RE: The tariff classification of a wallet and various bags from China
Dear Ms. Pray:
In your letter dated June 19, 2017, you requested a tariff classification ruling. You have submitted five samples with your request identified as styles Aimee, Lauryn, Alis, Chris, and Anccel. The samples will be returned to you under separate cover.
Style Aimee is a wallet constructed with an exterior surface of reinforced plastic sheeting. The wallet has two compartments, one is designed with a billfold section and zippered coin holder while the other has slots to hold credit cards. The wallet secures with a zipper for each compartment and measures approximately 7” (w) x 3.5” (h) with a 1.5” gusset.
Style Lauryn is comprised of a handbag and a removable pouch. Both items are constructed with an exterior surface of polyvinyl chloride (PVC), a plastic sheeting. The handbag is designed and sized to contain the small personal effects normally carried on a daily basis. It has a textile-lined storage compartment that is divided by a center zippered pocket. One section has three open pockets, while the other section has a zippered pocket on the sidewall. The bag has an open top with a magnetic snap closure and a removable shoulder strap. It measures approximately 14” (w) x 9.5” (h) with a 4.5” gusset. The removable pouch is fastened to the bag with a lobster claw clasp. It features a lined interior and a zippered closure across one exterior side panel and a carrying strap. The pouch measures approximately 8” (w) x 5.5” (h).
The handbag and pouch are considered a set for tariff purposes, General Rule of Interpretation (GRI) 3(b) of the Harmonized Tariff Schedule of the United States (HTSUS) noted. The essential character of the set is imparted by the handbag.
Style Alis is a handbag constructed with an exterior surface of bovine leather. The bag is designed and sized to contain the small personal effects normally carried on a daily basis. The bag has a textile-lined storage compartment that is divided by a center zippered pocket. One section has an open pocket while the other section has a zippered pocket on the sidewall. The bag has two carry handles, an open top with a magnetic snap closure, a front exterior pocket with a twist-lock closure and a removable shoulder strap. It measures approximately 13” (w) (at the top) x 9.5” (h) with a 7” gusset.
Style Chris is comprised of a tote bag and a removable pouch. Both items are constructed with an exterior surface of polyvinyl chloride (PVC), a plastic sheeting. The tote bag is designed to provide storage, organization, protection, and portability to clothing and other personal effects during travel. The tote bag has a textile-lined storage compartment with a center zippered pocket. It also has three interior open pockets and one small zippered pocket. The bag has two handles and an open top with a magnetic snap closure. It measures approximately 17” (w) x 13” (h) with a 5” gusset. The removable pouch is fastened to the bag with a lobster claw clasp. It features a lined interior and zippered closure across one exterior side panel and a carrying strap. The pouch measures approximately 8” (w) x 5.5” (h).
The tote bag and pouch of style Chris are considered a set for tariff purposes, GRI 3(b) of the HTSUS noted. The essential character of the set is imparted by the tote bag.
In your letter, you suggest classification of the tote bag under subheading 4202.22.1500, HTSUS, which provides in part, for handbags, whether or not with shoulder strap, including those without handle, with outer surface of sheeting of plastic. Classification under the HTSUS is made in accordance with the GRI’s. Pursuant to GRI 1, goods shall be determined according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes under the heading that most specifically describes them. The tote bag is designed and sized to contain the larger personal effects that would normally be carried in a travel bag such as clothing, books, sundry articles or food. Thus, the tote bag is more appropriately classified in the subheading that provides for travel, sports, and similar bags.
Style Anccel is a handbag constructed with an exterior surface of bovine leather. The bag is designed and sized to contain the small personal effects normally carried on a daily basis. It has a textile-lined storage compartment that is divided by a center zippered pocket. One section has two open wall pockets while the other section has a zippered pocket on the sidewall. The bag has a single carry handle and a magnetic flap closure adorned with a tassel. It measures approximately 13” (w) x 11” (h) with a 5” gusset.
The applicable subheading for Style Aimee will be 4202.32.1000, HTSUS, which provides for articles of a kind normally carried in the pocket or the handbag, with outer surface of sheeting of plastic or of textile materials, with outer surface of sheeting of plastics, of reinforced or laminated plastics. The rate of duty will be 12.1 cents per kilogram plus 4.6 percent ad valorem.
The applicable subheading for Style Lauryn will be 4202.22.1500, HTSUS, which provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of sheeting of plastic. The rate of duty will be 16 percent ad valorem.
The applicable subheading for Styles Alis and Anccel will be 4202.21.9000, HTSUS, which provides for handbags, whether or not with shoulder straps, including those without handle, with outer surface of leather, other, valued over $20 each. The rate of duty will be 9 percent ad valorem.
The applicable subheading for Style Chris will be 4202.92.4500., HTSUS, which provides for travel, sports and similar bags: with outer surface of sheeting of plastic or of textile materials: other. The rate of duty will be 20 percent 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 https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division