CLA-2-42:OT:RR:NC:N4:441
Angie McDaniel
Johnny Was
752 S. Victory Drive
Lyons, GA 30436
RE: The tariff classification of a tote bag from China and two additional bags from Hong Kong
Dear Ms. McDaniel:
In your letter dated June 12, 2025, you requested a tariff classification ruling. You have submitted
photographs, product information, and samples for our review. Your samples will be returned to you under
separate cover.
Style J06725-O is a tote bag constructed of 82% rayon, 18% silk textile material. It is designed and sized to
provide storage, protection, portability, and organization to personal effects during travel. It features one
adjustable shoulder strap, a drawstring, and one interior pocket. It measures approximately 14.5” (W) x 13.5”
(H) x 1” (D). You have indicated the country of origin is China.
Style M61225 is a handbag constructed of 100% cotton textile material. It is designed and sized to contain
the small personal effects normally carried on a daily basis. It features one shoulder strap and a top opening.
It measures approximately 9.75” (W) x 9.5” (H) x 1” (D). You have indicated the country of origin is Hong
Kong.
Style M61325 is a tote bag constructed of 100% cotton textile material. It is designed and sized to provide
storage, protection, portability, and organization to personal effects during travel. It measures approximately
15” (W) x16.5” (H) x 0.5” (D). You indicated the country of origin is Hong Kong.
The applicable subheading for style J06725-O will be 4202.92.3131, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for travel, sports, and similar bags, with outer surface of textile
material, other, other, of man-made fibers. The general rate of duty will be 17.6 percent ad valorem.
The applicable subheading for style M61325 will be 4202.92.1500, HTSUS, which provides for travel,
sports, and similar bags, with outer surface of textile materials, of vegetable fibers and not of pile or tufted
construction, of cotton. The general rate of duty is 6.3 percent ad valorem.
The applicable subheading for style M61225 will be 4202.22.4500, HTSUS, which provides handbags,
whether or not with shoulder strap, including those without handle, with outer surface of textile materials, of
vegetable fibers and not of pile or tufted construction, of cotton. The general rate of duty will be 6.3 percent
ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4202.92.3131, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate 9903.88.03 of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
in addition to subheadings 4202.92.3131, HTSUS, listed above.
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. 9903.01.2 4, in addition
to subheadings 4202.92.3131, 4202.92.1500, and 4202.22.4500, 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. At this time products from all 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. 9903.01.25, in addition to subheadings
4202.92.3131, 4202.92.1500, and 4202.22.4500, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division