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HQ 086771

July 17, 1990

CLA-2 CO:R:C:G 086771 SLR


TARIFF NO.: 4202.22.1500

Ms. Aphrodite Leung
Winncie Industrial Co.
RM. 4-6, 10/F., Eureka Ind. Bldg.
1-17 Sai Lau Kok Rd.
Tsuen Wan, N.T., Hong Kong

RE: Handbags

Dear Ms. Leung:

This ruling is in response to your letter of March 8, 1990, requesting the proper classification for a variety of handbags under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). A color brochure depicting 20 various styles, along with a sample of item number 9001, was submitted for our examination.


Item 9001 measures approximately 12-1/2" x 9" x 3-1/2" and has double shoulder straps, two interior compartments, and two exterior open pockets. The handbag consists of imitation leather PVC plastics material, with a textile tapestry panel covering a portion (approximately 1/3) of the front. The main portion of the bag's body is composed of PVC plastics material.

In the absence of samples, we are unable to provide a ruling for the other items described in the submitted brochure.


What is the proper classification of the subject handbag under the HTSUSA?


Classification of merchandise under the HTSUSA is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that classification is determined according to the terms of the headings and any relative section or chapter notes.

Heading 4202, HTSUSA, provides for, among other articles, handbags. This heading accurately describes item 9001.

At the six-digit subheading level, Heading 4202 provides for handbags with an outer surface of plastic sheeting or of textile materials. Included within this provision are handbags whose outer surface is substantially constructed of either plastic sheeting or textile materials. The subject handbag so qualifies.

At the eight-digit level, Heading 4202 includes two subheadings -- one providing for handbags with an outer surface of plastic sheeting, and the other providing for handbags with an outer surface of textile materials. In order to determine the specific eight-digit subheading applicable to the instant handbag, we must decide whether the handbag's outer surface is composed of plastic sheeting or of textile materials. As mandated by GRI 2(b), the classification of goods consisting of more than one material shall be determined by the application of GRI 3.

GRI 3(a) directs that goods shall be classified under the subheading which provides the most specific description. Two or more subheadings are regarded as equally specific, however, when each refers to part only of the materials. Consequently, GRI 3(b) must be consulted.

GRI 3(b) directs that composite goods consisting of different materials shall be classified as if they consisted of the material which gives them their essential character. The Explanatory Notes for GRI 3(b) indicate that "essential character" may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of the constituent material to the use of the goods.

It is our determination that the PVC plastics sheeting material imparts the essential character of the handbag's outer surface. The bulk, quantity, and weight of the plastic sheeting greatly surpasses that of the textile tapestry panel.


Item 9001 is classifiable in subheading 4202.22.1500, HTSUSA, which provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of plastic sheeting. The correct rate of duty is 20 percent ad valorem. No visa or quota restraints apply.


John Durant, Director
Commercial Rulings Division

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