CLA-2-42:OT:RR:NC:N4:441
Vincent Glaviano
Ubavu
1498 Canyon Blvd, #201
Boulder, CO 80304
RE: The tariff classification of an insulated cooler bag from China
Dear Mr. Glaviano:
In your letter dated August 12, 2025, you requested a tariff classification ruling. You have submitted a
sample, photographs, and descriptive literature for our review.
The article at issue is an insulated cooler bag constructed with an outer surface of man-made textiles. It is
designed to provide storage, protection, portability and organization to food, beverages, and other personal
effects. It will also maintain the temperature of food and beverages. The cooler will be imported with related
accessories to aid in the maintenance of the food and beverages such bottle covers and freezer packs. The
cooler and accessories are considered a set for tariff purposes, General Rule of Interpretation 3(b) of the
Harmonized Tariff Schedule of the United States (HTSUS) noted. The essential character of the set is
imparted by the cooler because it is the primary component which has the most bulk and it serves it purpose
with or without the accessories, which will simply serve to enhance the cooler on an as needed basis.
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. At this time, products of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 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 xx 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 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)
Denise Faingar
Acting Director
National Commodity Specialist Division