CLA-2-:OT:RR:NC:N4:441
Marilyn Santos
Supreme International
3000 NW 107th Avenue
Miami, FL 33172
RE: The tariff classification of an insulated cooler bag from China
Dear Ms. Santos:
In your letter dated March 25, 2025, you requested a tariff classification ruling. You have submitted a
sample, which will be returned under separate cover.
The submitted sample, style number AVASG012, is an insulated cooler bag with an outer surface of a
man-made textile material. It is designed to provide storage, protection, organization, and portability to food
and beverages during travel. The bag is also designed to maintain the temperature of food and beverages.
There is a layer of foam plastics between the exterior of the bag and the lining. The article features a zippered
closure at the top, one handle, and one adjustable shoulder strap. The front features one zippered pocket with
a permanently attached metal bottle opener. It measures 9 inches (L) by 5.5 inches (W) by 11.5 inches (H).
You inquired whether the Section 232 additional duties on certain derivative steel products applies to the
Section 232. Articles of subheading 4202.92.0807, Harmonized Tariff Schedule of the United States
(HTSUS), are not among those listed in Annex 1 to Presidential Proclamation 10896.
The applicable subheading for the insulated cooler bag will be 4202.92.0807, HTSUS, which provides for
insulated food and beverage bags, with outer surface of sheeting of plastic or of textile materials, with outer
surface of textile materials, other, of man-made textiles. The general duty rate will be 7 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 4202.92.0807, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs.? ?All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs.? Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. ?Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.63, in addition to
subheading 4202.92.0807, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4202.92.0807, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 4202.92.0807, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Vikki Lazaro at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division