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HQ 957360

January 30, 1995

CLA-2 CO:R:C:T 957360 ch


TARIFF NO.: 4202.32.1000

Marty Langtry
Tower Group International, Inc.
5420 W. 104th Street
Los Angeles, California 90045-6069

RE: Tariff classification of accessories from China; articles of a kind normally carried in the pocket or in the handbag; wallet.

Dear Mr. Langtry:

This is in response to your letter of October 13, 1994, on behalf of Tower Group International, Inc., requesting tariff classification under the Harmonized Tariff Schedule of the United States (HTSUS) for three articles described as fold-over wallets. Please be advised that we are retaining the samples in order to facilitate uniformity of classification in this area.


The submitted samples, styles 30500, 30501 and 36422, are tri-fold accessories with detachable shoulder straps. They measure approximately 7 1/2 inches by 4 1/2 inches in their closed position. These items possess an outer surface of plastic sheeting which has been laminated to a textile material backing. The articles feature interior slots for credit and identification cards, pockets for coins and paper currency, a checkbook holder and pen loops. The exterior includes a full width gusseted utility pocket secured by means of hook and loop fastener material.


Whether the subject merchandise is classifiable in subheading 4202.22, HTSUS, which provides for handbags; or subheading 4202.32, HTSUS, which provides for articles of a kind normally carried in the pocket or in the handbag?


Heading 4202, HTSUS, provides inter alia for handbags and wallets. Subheading 4202.22, HTSUS, encompasses handbags; subheading 4202.32, HTSUS, describes articles of a kind normally carried in the pocket or handbag. The subheading Explanatory Note to heading 4202, at page 613, indicates that wallets are classified within subheading 4202.32. Pursuant to General Rule of Interpretation 6, classification of goods at the subheading level shall be effected mutatis mutandis with General Rules of Interpretation 1 through 5.

The term "wallet" is not defined in the HTSUS or in the applicable Explanatory Note to heading 4202, HTSUS. However, we note the following definitions of the term "wallet" from lexicographic sources:

Essential Terms of Fashion: A Collection of Definitions, Charlotte M. Calasibetta, Fairchild Publications, 1986: An item used to carry paper money, credit cards, photographs and sometimes with a change purse or space for a check book or pad.

The Fashion Dictionary, Mary Brooks Picken, Funk & Wagnalls, 1973: 1. Flat purse or pocketbook, for carrying either paper money or coins.

Webster's New Collegiate Dictionary, G. & C. Merriam Co., 1977: 1. a bag for carrying miscellaneous articles while traveling; 2 a: billfold b: a pocketbook with compartments for change, photographs, cards, and keys.

Webster's New World Dictionary, Third College Edition, Simon & Schuster, Inc., 1988: 1. [Archaic] a knapsack; 2. a flat pocketbook, as of leather, with compartments for paper money, cards, etc.; billfold.

We also recognize that the term "handbag" has been defined as follows:

Essential Terms of Fashion: A Collection of Definitions: Accessory carried primarily by women and girls to hold such items as money, credit cards, and cosmetics.

The Fashion Dictionary: Soft or rigid bag carried in hand or on arm. Size, shape, handle, etc., depend on fashion. Used by women as container for money and pocket-sized accessories.

Webster's New Collegiate Dictionary: 1. traveling bag; 2. a woman's bag held in the hand or hung from a shoulder strap and used for carrying small personal articles and money.

Webster's New World Dictionary: A bag, usually of leather or cloth, held in the hand or hung by a strap from the arm or shoulder and used, by women, to carry money, keys, and personal effects.

The submitted samples possess attributes of both wallets and handbags. For example, they feature credit card slots, pockets for paper currency/coins and identification card windows, which are associated with wallets. On the other hand, these articles possess a shoulder strap and an exterior utility pocket. As the samples are described by two subheadings within heading 4202, HTSUS, we must resort to General Rule of Interpretation 3, in conjunction with General Rule of Interpretation 6, to determine their proper classification.

Although the presence of a carrying strap permits the articles to be worn on the shoulder in a manner consistent with a handbag, we conclude that a strap in and of itself should not affect their classification. In this regard, we note that the provision for handbags specifies that handbags may or may not have a shoulder strap. Moreover, in this instance the straps are detachable, suggesting a dual use for the merchandise as articles to be carried in a handbag. It should also be noted that as a class of merchandise wallets are normally carried in the pocket or in the handbag, notwithstanding the fact that it has recently become popular to carry these items by means of a shoulder strap.

Furthermore, we are of the opinion that the determinative feature of a handbag is its ability to hold several objects not associated with a wallet. In this instance, the articles are fitted to hold objects associated with a wallet as they are flat and possess slots and pockets to hold credit cards, identification cards, paper currency and coins. In addition, they are of a size suitable for carrying in a handbag. We note that the addition of the exterior pocket is a step in the direction of a handbag, as the article begins to take the character of a carry-all container. However, the exterior pockets are relatively flat and do not possess sufficient capacity to hold small personal effects which are typically carried in the handbag (e.g. hairbrush, cosmetics, keys on a chain). Consequently, in this instance we conclude that the merchandise is most specifically described by the provision for articles of a kind normally carried in the pocket or in the handbag.


The subject merchandise is classifiable under subheading 4202.32.1000, HTSUS, which provides for articles of a kind normally carried in the pocket or in the handbag: with outer surface of sheeting of plastic: or reinforced or laminated plastics. The applicable rate of duty is 12.1 cents/kilogram + 4.6 percent ad valorem.


John Durant, Director

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