CLA-2-42:OT:RR:NC:N4:441

Aneta Skromak
Helmut Lang New York LLC
165 Polito Avenue Lyndhurst, NJ 07071

RE:  The tariff classification of a travel bag, with an additional storage component, from India

Dear Ms. Skromak:

In your letter, dated November 19, 2024, you requested a tariff classification ruling.  You have submitted a sample, which will be returned under separate cover.  

Style# HLM78248 is comprised of two components constructed of genuine cow leather. The first component is a cross-body utility bag. The second component has been described as a “half vest.”  Each component has one side of a complete zipper which allows the two components to be connected.

The utility bag, as a separate component, is considered a cross-body travel bag for classification purposes. The bag measures approximately 10” (L) x 16” (W) x 4.5” (D) and has several zippered compartments suitable to contain the larger personal effects associated with travel. It is classifiable in Heading 4202.

The half vest is not considered a garment or accessory for classification purposes. It is specifically designed and adapted to attach to the bag as needed to provide additional storage and support to the bag. If imported on its own, it would be classified in Heading 4205 as an article of leather.

As the two components are adapted to each other, they are considered composite goods for tariff purposes, General Rule of Interpretation 3(b) of the Harmonized Tariff Schedule (HTSUS), noted. The principal purpose of the complete two-piece article is to provide storage, protection, portability, and organization to personal effects.  As such, the essential character is imparted by the travel bag.

The applicable subheading for style# HLM78248 will be 4202.91.9030, HTSUS, which provides for travel, sports, and similar bags, with an outer surface of leather. The rate of duty will be 4.5% 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 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,

Steven A. Mack
Director
National Commodity Specialist Division