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HQ 088798

October 21, 1991

CLA-2 CO:R:C:T 088798 CC


TARIFF NO.: 4202.32.1000

Mr. Louis S. Shoichet
Siegel, Mandell & Davidson
One Whitehall Street
New York, NY 10004

RE: Classification of a vinyl wallet/key chain; classifiable in Heading 4202

Dear Mr. Shoichet:

This letter is in response to your inquiry on behalf of Avon Products, Inc., requesting the tariff classification of a "Vinyl Wallet/Key Chain." A sample was submitted for examination.


The submitted sample, designated as item PP 96902, is a bi- fold wallet measuring approximately three inches in height and four inches in width when closed. This article is constructed of a vinyl fabric which is composed of a three layer construction of a fabric backing, a cellular plastics middle layer, and a compact vinyl outer layer, which is printed with a multi-color paisley design. In the folded position the wallet is secured by a plastic clasp with a metal snap. The interior of the wallet has spaces for credit cards and other accessories, a detachable key ring which is secured to the interior by a metal snap, and a zippered change/currency compartment.


Whether the merchandise at issue is classifiable in Heading 4202 of the Harmonized Tariff Schedule of the United States Annotated (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 shall be determined according to the terms of the headings and any relative section or chapter notes.

Heading 4202, HTSUSA, encompasses all travel goods, handbags and similar containers. Subheading 4202.32., in particular, provides for articles carried in the pocket or handbag, with outer surface of plastic sheeting. Moreover, the Explanatory Notes, the official interpretation of the HTSUSA at the international level, state that this subheading covers articles of a kind normally carried in the pocket or in the handbag and includes spectacle cases, note-cases (bill-folds), wallets, purses, key-cases, cigarette-cases, cigar-cases, pipe-cases, and tobacco-pouches.

The container in question is similar to the articles specified in the second part of Heading 4202, i.e., purses and wallets, and is wholly or mainly covered with plastic sheeting. The Explanatory Notes for 4202.32 indicate that this subheading applies to articles of a kind normally carried in the pocket or in the handbag. Therefore, the merchandise at issue is classifiable in Heading 4202.


The submitted merchandise is classified under subheading 4202.32.1000, HTSUSA, which provides for traveling bags, toiletry bags, knapsacks and backpacks, handbags, shopping bags, wallets, purses, map cases, cigarette cases, tobacco pouches, tool bags, sports bags, bottle cases, jewelry boxes, powder cases, cutlery cases and similar containers, of leather or of composition leather, of plastic sheeting, of textile materials, of vulcanized fiber or of paperboard, or wholly or mainly covered with such materials, articles of a kind normally carried in the pocket or in the handbag, with outer surface of plastic sheeting or of textile materials, with outer surface of plastic sheeting, of reinforced or laminated plastics. The rate of duty is 12.1 cents per kilogram plus 4.6 percent ad valorem. Currently no textile category is applied to merchandise classified under this subheading.

The sample is being returned under separate cover.


John Durant, Director

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