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HQ 951407

June 15, 1992

CLA-2 CO:R:C:T 951047 CRS


TARIFF NO.: 4202.32.1000

Steven S. Weiser, Esq.
Paul A. Horowitz, Esq.
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway, 43rd Floor
New York, NY 10036

RE: Wallets; flat goods; articles of a kind normally carried in the pocket or the handbag; of reinforced or laminated plastics; HRL 950048, HRL 950567 and HRL 950983 cited.

Dear Messrs. Weiser and Horowitz:

This is in reply to your letter of March 19, 1992, on behalf of Michael Stevens Ltd., concerning the classification of certain flat goods under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).


The merchandise at issue consists of five styles of wallets (flat goods) imported from the People's Republic of China. All of the styles have outer pockets or compartments (a zippered pocket on styles 25002, 25005 and 28303, and a coin purse with snap closure on styles 25021 and 25055). The interiors of all of the articles contain credit card slots and bill slides, with styles 25005, 25051 and 28303 also having zippered compartments near the bill slide area. Style 25002 has a zippered closure; the remaining four styles have snap closures.

Each style has an outer surface of polyvinyl chloride (PVC) sheeting to which a textile fabric backing has been bonded by the application of heat (which activates a glue that has been applied to the textile fabric) and pressure. Styles 25002, 25005, 25021 and 25055 have a woven fabric backing; style 28303 has a nonwoven backing. It is anticipated that shipments of the merchandise in question will be entered through the ports of Newark and Los Angeles.


The issue presented is whether the instant wallets are "of reinforced or laminated plastics" such that they are classifiable in subheading 4202.32.1000, HTSUSA.


Heading 4202, HTSUSA, provides, inter alia, for wallets. The instant merchandise consists of five styles of wallets. The articles in question are provided for eo nomine in heading 4202 and are therefore classifiable accordingly.

Subheading 4202.32, HTSUSA, provides for articles of a kind normally carried in the pocket or handbag with an outer surface of plastic sheeting or of textile materials. The Explanatory Notes (EN), while not legally binding, are considered by Customs to constitute the official interpretation of the Harmonized System at the international level. The Subheading Explanatory Note to EN 42.02 states that the provision for articles of a kind normally carried in the pocket or the handbag includes wallets.

Additional U.S. Note 2, Chapter 42, HTSUSA, provides that for the purposes of classifying articles in subheading 4202.32:

[A]rticles of textile fabric impregnated, coated, covered or laminated with plastics (whether compact or cellular) shall be regarded as having an outer surface of textile material or of plastic sheeting, depending on whether and the extent to which the textile material or the plastic constituent makes up the exterior surface of the article.

Plastics makes up virtually all, if not the entire surface of the wallets in question. Accordingly, the five styles of wallets at issue, all of which have an outer surface of plastics, are classifiable in subheading 4202.32, HTSUSA.

Subheading 4202.32.1000, HTSUSA, provides for articles of a kind normally carried in the pocket or handbag, i.e., flat goods, with an outer surface of reinforced plastics. Customs has held that flat goods of similar construction to the merchandise at issue was "of reinforced or laminated plastics" for the purposes of subheading 4202.32.1000, HTSUSA. Headquarters Ruling Letter (HRL) 950048 and HRL 950567 dated March 2, 1992; HRL 950983 dated June 15, 1992.


The five styles of merchandise at issue are classifiable in subheading 4202.32.1000, HTSUSA, under the provision for 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. They are dutiable at the rate of 12.1 per kilogram plus 4.6 percent ad valorem.


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