CLA-2-42:OT:RR:NC:N4:441
Debra Dudzinski
GBG Accessories Group, LLC
4620 Grandover Parkway
Greensboro, NC 27407
RE: The tariff classification of handbags and a tote bag from Cambodia
Dear Ms. Dudzinski:
In your letter dated August 21, 2018, you requested a tariff classification ruling. You have submitted four samples which will be returned to you under separate cover.
Style 50431 is a handbag with an outer surface constructed of polyurethane (PU) plastic sheeting. The handbag is designed and sized to contain the small personal effects that would normally be carried on a daily basis. The handbag features a textile-lined interior storage compartment with one zippered pocket and two open pockets, two carrying handles and a top zippered closure at the center of the bag. The exterior of the bag has a front and rear open pocket. It measures approximately 12” (w) x 10” (h) x 6” (d).
Style 50439 is a handbag with an outer surface constructed of polyurethane (PU) plastic sheeting. The handbag is designed and sized to contain the small personal effects that would normally be carried on a daily basis. The handbag features a textile-lined storage area with one zippered wall pocket and one open wall pocket, a top zippered closure and an adjustable shoulder strap. The front panel has a pocket with a snap closure and the rear panel has an open slip pocket. It measures approximately 9 ¼” (w) x 9 ¼” (h) x ¾” (d).
Style 50443 is a tote bag constructed with an outer surface of polyurethane (PU) plastic sheeting. The tote bag is designed and sized to contain the large personal effects during travel. The tote bag features a textile-lined interior compartment with one zippered wall pocket and two open wall pockets, two carrying handles, and a top opening secured with a center zipper closure. It has two exterior pockets on each side of the bag; one is an open slip pocket and the other has a magnetic snap closure. The tote bag measures approximately 16” (w) x 12” (h) x 5 ½” (d).
Style 50450 is a handbag with an outer surface constructed with an outer surface of polyurethane (PU) plastic sheeting. It is designed and sized to contain the small personal effects that would normally be carried on a daily basis. The handbag features a textile-lined interior compartment divided into three compartments. The interior has one zippered center compartment and two open sections on each side. The handbag has a flap with a snap closure and a removable shoulder strap. It measures approximately 7 ¾” (w) x 5 ¾” (h) x 1” (d).
In your letter, for style 50431, you suggest classification under subheading 4202.92.4500, Harmonized Tariff Schedule of the United States, (HTSUS) which provides for travel, sports, and similar bags, with outer surface of plastic sheeting material, other. Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRI). 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 handbag is not designed or sized to contain the larger personal effects that would normally be carried in a travel bag such as clothing, books, sundry articles or food. The bag is more specifically classified under subheading 4202.22.1500, HTSUS.
The applicable subheading for styles 50431, 50439, and 50450 will be 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. The rate of duty will be 16 percent ad valorem.
The applicable subheading for style 50443 will be 4202.92.4500, HTSUS, which provides for travel, sports, and similar bags, with outer surface of plastic sheeting material, other. The rate of duty will be 20 percent ad valorem.
In your submission, you state that bulk rolls of Chinese fabric will be exported from China to Cambodia. In Cambodia, the fabric will be cut, sewn, laminated, and glued to create the finished articles described above. Pursuant to Part 134, Customs Regulations (19 CFR Part 134), Section 134.1(b), the country of origin is the country of manufacture, production or growth of any article of foreign origin entering the U.S. Further work or material added to a foreign article in another country must effect a substantial transformation in order to render the final product a good of the other country. In the manufacture of these bags, the substantial transformation occurs when the bulk fabric is cut into component pieces and assembled into to finished article. Because these manufacturing procedures occur in Cambodia, the country of origin of the bags above is Cambodia.
Articles classifiable under subheading 4202.22.1500 and 4202.92.4500, HTSUS, which are products of Cambodia are currently entitled to duty-free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP, however, is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web ite at www.cbp.gov and search for the term “GSP.”
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