CLA-2-63:OT:RR:NC:N3:351
Ms. Colleen Brennan
VF Outdoor DIV Kipling
525 Washington Boulevard
Jersey City, NJ 07310
RE: The tariff classification of textile bag charms from Cambodia
Dear Ms. Brennan:
In your letter dated September 12, 2025, you requested a tariff classification ruling. In lieu of a sample,
photographs of two textile bag charms were provided with your request.
Style K16479, described as a “Sven Monkey Keychain,” is a textile charm depicting a monkey designed to
be attached to a handbag. The monkey shaped charm is composed of 72 percent acrylic and 28 percent
polyester knit fabric and stuffed with polyester filling. The face and hands of the monkey are composed of
100 percent polyvinyl chloride (PVC). A keychain with a steel split key ring is attached to the head of the
monkey. The charm measures 1 ¾ inches in length by 2 inches in height. You state the bag charm can be
imported either attached to a handbag or separately. This ruling will only address the bag charms when
imported separately.
Style KI9589, described as a “Jean Cap Keychain,” is a textile charm depicting a baseball cap designed to be
attached to a handbag. The baseball cap shaped charm is composed of 100 percent cotton woven fabric and
stuffed with polyester filling. A lobster claw clasp keychain is attached to the top of the baseball cap. The
charm measures 3 ¼ inches in length by 4 ¼ inches in height. You state the bag charm can be imported
either attached to a handbag or separately. This ruling will only address the bag charms when imported
separately.
You suggested that the “Sven Monkey Keychain” and the “Jean Cap Keychain” be classified under
subheading 7326.20.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“Other articles of iron or steel: Articles of iron or steel wire: Other.” We disagree.
The “Sven Monkey Keychain” and the “Jean Cap Keychain” charms are composite goods consisting of a
made up textile article (heading 6307) and a metal keychain (heading 7326). General Rule of Interpretation
(GRI) 1, HTSUS, states in part that for legal purposes, classification shall be determined according to the
terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the
remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are
classifiable in accordance with GRI 3. GRI 3(a) states that the heading which provides the most specific
description shall be preferred to headings providing a more general description. However, when two or more
headings refer to part only of the items in a composite good, those headings are to be regarded as equally
specific in relation to the goods, even if one of them gives a more complete or precise description of the
good. As such, they are regarded as equally specific and classification of the composite good is to be
determined by GRI 3(b) or GRI 3(c). GRI 3(b) states in part that composite goods, which cannot be
classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives
them their essential character which may be determined by the nature of the material or component, its bulk,
quantity, weight or value, or by the role of a constituent material in relation to the use of the article. In this
case, we find the essential character of the charms to be the textile component. The textile component
provides aesthetic appeal and marketability, while the steel split ring and claw hook are intended to facilitate
the connection between the charm and a handbag. As such, the split ring and claw hook are subservient to
the charm and not principally intended for holding keys during routine use.
The applicable subheading for the “Sven Monkey Keychain” and the “Jean Cap Keychain” when imported
separately from a handbag will be 6307.90.9891, HTSUS, which provides for “Other made up articles,
including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem.
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 Cambodia
will be subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.11, in addition to subheading
6307.90.9891, 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, available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 Kristine Dodge at [email protected]
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division