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HQ 955552

August 15, 1994

CLA-2 CO:R:C:T 955552 NL


Tariff NO.: 4202.22.6000

Arlen T. Epstein, Esq.
Serko & Simon
One World Trade Center
New York, NY 10048

RE: Tariff Classification of a Ramie and Cotton Shoulder Bag

Dear Sir:

This is in reply to your letter of December 14, 1993, in which you requested a ruling concerning the tariff classification of a ramie and cotton shoulder bag for women on behalf of Sarne Corporation.


The submitted sample, item number 18052 (HK 5339), is a pink lady's shoulder bag designed to be carried tucked under the arm and over the shoulder. The shoulder bag measures approximately 14 inches in width by 9 1/2 inches in height, with a tapered gusset two inches wide at the top and four inches wide at the bottom. According to the report of the Customs Laboratory in New York (Report 2-94-10662-001), the material consists of 57 percent ramie and 43 percent cotton. The bag has two shoulder straps of approximately 26 inches in length. The bag is divided into two separate compartments by a divider. Each compartment may be closed with a zipper. One compartment has a zippered change purse. The interior of the bag is lined, and the bottom and corners are reinforced.

You urge classification of the article as a handbag under subheading 4202.22, HTSUS.


Whether the merchandise is considered a handbag or a travel, sports or similar bag under the HTSUS.


Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). The systematic detail of the harmonized system is such that virtually all goods are classified by application of GRI 1, that is, according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes.

Heading 4202, HTSUS, provides for, among other things, trunks, suitcases, briefcases, traveling bags, handbags, shopping bags, sports bags, and other similar containers of, among other materials, textile materials. Subheading 4202.22, HTSUS, provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of plastic or of textile materials. Subheading 4202.92, HTSUS, provides for, among other things, travel, sports and similar bags, with outer surface of sheeting of plastic or of textile materials.

Your submission refers several times to this bag as a "tote", although at other times you refer to it as a "shoulder bag". The report of the National Import Specialist indicates that the correct common terminology for this bag is "shoulder bag". You note that in several ruling letters issued by Customs Headquarters (HRLs 088662; 950708; and 950709), "tote" bags have been held to be classifiable as travel, sports, and similar bags as provided in subheading 4202.92, HTSUS. Customs considered the bags in question, which were of relatively coarse canvas material, and had either a single closure or no closure, to be unlikely to be used in the manner of a woman's handbag of subheading 4202.22.

You contend, and we agree, that the instant bag is distinguishable from these "tote" bags previously considered. We do not believe it is a multipurpose bag used to carry a number of articles such as food, books, or clothing, or that it is suitable for travel. Nor is it a bag for shopping. While the bag could conceivably be employed for some limited use as a sports bag, we think it is clear that the primary purpose of the bag is as a traditional woman's handbag. Its design and construction, notably the shoulder straps, reinforcement, inside zipper pocket, and style of compartmentalization and zipper closure, are all strongly indicative of a bag which is used normally by women and girls to carry personal items on a daily basis. Accordingly, this bag is classifiable as a handbag.


The Sarne Style 18052 bag is classified at subheading 4202.22.6000, HTSUS, which provides for handbags, whether or not with shoulder strap, with outer surface of sheeting of plastic or of textile materials: Other: of vegetable fibers and not of pile or tufted construction: Other. The rate of duty is 6.5 percent ad valorem. The textile category is 871.


John Durant
Director, Commercial

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