CLA-2-46:RR:NC:SP:230 D81902

Ms. Teresa A. Raffa
Associated Merchandising Corporation
1440 Broadway
New York, N.Y. 10018

RE: The tariff classification of handbags made of woven imitation-leather strips, from China.

Dear Ms. Raffa:

In your letter dated September 1, 1998, you requested a tariff classification ruling.

Four ladies' "vinyl handbags" (styles S19120, S19118, S19105 and S19149B) were submitted as samples and are being returned to you as requested. Although they differ in aspects such as color, shape, arrangement of interior compartments and type of closure, they share the same basic kind of construction. The side panels (which comprise the majority of the surface area of each bag's shell) are made up of narrow, interwoven strips of imitation leather. The bottoms, ends (gussets) and carrying straps are made of smooth, continuous sheets of imitation leather. All of the bags are lined with woven textile fabric.

For tariff purposes, we find that the interwoven imitation-leather strips impart the essential character to the handbags. The individual strips consist of cellular plastic backed with a nonwoven textile material. Each strip measures approximately 3 mm in width. As such, these strips are not considered man-made textile materials of Section XI of the Harmonized Tariff Schedule of the United States (HTSUS), specifically Chapters 54 and 56. Rather, they are plastic strips of heading 3921, HTSUS, which provides for certain plates, sheets, film, foil and strip of plastics. Plastic strips of Chapter 39, HTSUS, may be considered "plaiting materials" as defined in Chapter 46, Note 1. Articles made up from plaiting materials of plastics of Chapter 39, HTSUS, by weaving or similar processing are classifiable as manufactures of plaiting materials in Chapter 46, HTSUS.

Accordingly, the applicable subheading for the four styles of "vinyl handbags" will be 4602.90.0000, HTSUS, which provides for other (non-enumerated) articles of plaiting materials. The rate of duty will be 3.9%. 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 Paul Garretto at 212-466-5779.

Sincerely,

Robert B. Swierupski
Director,
National Commodity Specialist
Division