CLA-2-42:OT:RR:NC:N4:441
Ms. Sandy Pray
Camuto Group
DBA VCS Group, LLC.
32 Springside Road
Westampton, NJ 08060
RE: The tariff classification of handbags from China
Dear Ms. Pray:
In your letter dated February 22, 2019, you requested a tariff classification ruling. You have submitted samples, which will be returned to you under separate cover.
Style VC-RAYA-SA is a leather handbag designed and sized to contain the small personal effects normally carried on a daily basis. The bag features a magnetic-flap closure, two handles, and an adjustable shoulder strap. The interior has a zippered wall pocket and two open pockets. The exterior has one pocket under a flap. The bag measures approximately 3.5 inches (W) x 11.5 inches (H) x 13.5 inches (D).
Style VC-ZEST-TO is a two-piece novelty handbag. The handles of the item are attached to a decorative, wide-mesh carrier that contains a textile insert. The insert has a magnetic-snap closure and two interior pockets. The mesh component has an open top. The insert, which serves as the storage compartment of the handbag, is constructed of cotton textile. The insert is placed inside the mesh component. Neither component is functional as a handbag on its own without the other. The two components are considered to be a composite good for tariff purposes, General Rule of Interpretation 3(b) noted. The cotton insert is the component which contains the personal effects. The insert also has a striking and colorful floral design seen through the mesh that creates the more pronounced visual impact. As such, the essential character of the handbag is provided by the cotton component.
In your request, you suggested classification of the leather handbag under 4202.91.9030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for travel, sports, and similar bags, with outer surface of leather. We disagree. This article does not have adequate storage capacity to accommodate the larger personal effects associated with travel or sports. The submitted sample is more properly classified as a handbag.
The applicable subheading for the leather handbag, if valued not over $20, will be 4202.21.6000, HTSUS, which provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of leather, of composition leather or of patent leather, other, valued not over $20 each. The general rate of duty will be 10 percent ad valorem.
The applicable subheading for the leather handbag, if valued over $20, will be 4202.21.9000, HTSUS, which provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of leather, of composition leather or of patent leather, other, valued over $20 each. The general rate of duty will be 9 percent ad valorem.
The applicable subheading for the two-piece handbag 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.
Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS.
For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974).
Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings. Products of China classified under subheading 4202.21.60, 4202.21.90, and 4202.22.45, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, 9903.88.03, in addition to subheading 4202.21.6000, 4202.21.9000, and 4202.22.4500, HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the notice cited above and the applicable Chapter 99 subheading. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
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 https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division