The tariff classification of a tote bag and accessories from China

N136177 January 5, 2011 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.92.4500, 3926.90.9980 Joyce M. Duquette Fossil Retrodome 10615 Sanden Drive Dallas, TX 75238 RE: The tariff classification of a tote bag and accessories from China Dear Ms. Duquette: In your letter dated December 1, 2010, you requested a tariff classification ruling. Your sample will be returned to you. The item submitted was not identified with a style number. The item is a tote bag with a removable luggage tag and key holder. For tariff purposes, the three pieces are not considered a set and will be classified separately. The bag is constructed of cotton canvas laminated on the outer surface with polyvinyl chloride (PVC) plastic sheeting. The entire front and back panels and the bottom portion of the bag are laminated with the plastic. The essential character is imparted by the front and back panels. The bag is designed to provide storage, organization, protection, and portability to clothing and other personal effects during travel. The interior of the bag is unlined with a hanging pocket on each side wall. It has an open top with a hidden magnetic closure and two carrying handles. The front exterior has an open pocket. It measures approximately 14.5” (W) x 13” (L) x 5” (D). The luggage tag/identification tag is constructed of cellular polyvinyl chloride (PVC) plastic sheeting backed with textile fabric for mere reinforcement. It measures approximately 3” by 2” and includes a pocket for an identification card that would be visible behind the clear plastic viewing window. The tag has a strap with metal buckle so that it may be attached onto a travel bag. The key holder consists of a slit strip of cellular PVC backed with textile fabric for mere reinforcement. The strip measures approximately 8” in length and is designed to be secured through the hole in the top of a key. The key holder includes a decorative molded plastic key shaped fob. In your letter, you suggest the tote bag should be classified as a handbag under subheading 4202.22.4500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for 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 tote bag is designed and 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 tote bag is more specifically classified under subheading 4202.92.4500, HTSUS. The applicable subheading for the tote bag will be 4202.92.4500, HTSUS, which provides for travel, sport, and similar bags, with outer surface of sheeting of plastic, other. The rate of duty will be 20% ad valorem. The applicable subheading for the luggage tag and key holder will be 3926.90.9980, HTSUS, which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem. 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 http://www.usitc.gov/tata/hts/. 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 (646) 733-3041. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division