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HQ 960883

April 27, 1998

CLA-2 RR:CR:GC 960883 DWS


TARIFF NO.: 6307

Ms. Estella Lopez-Baum
Tower Group International
2400 Maxine Avenue
Redondo Beach, CA 90278-1103

RE: Golf Bag Components; GRI 2(a); HQ 959178

Dear Ms. Lopez-Baum:

This is in response to your letter of October 21, 1997, to our office inquiring about the status of letters dated April 4 and June 13, 1997, submitted by Tower Group International on behalf of Wilson Sporting Goods, to the National Commodity Specialist Division of Customs, New York, concerning the classification of golf bag components under the Harmonized Tariff Schedule of the United States (HTSUS). The April 4 and June 13, 1997, letters were referred to this office for a response. We regret the delay.


The merchandise consists of five different shipments of golf bag components. After importation into the U.S., the components, along with U.S. components, will be assembled into complete golf bags. Each shipment contains the following:

Shipment 1:

- Golf bag body assembly and shoulder strap (both polyester textile woven fabric)

Shipment 2:

- Bottom cuff and top cuff/ring assembly (both polyester textile woven fabric)

- Full length golf club dividers/screws (separate polyester pieces which will be attached to plastic bottom and the top ring during final assembly)
- Dog biscuit (vinyl or leather), imported flat, which covers the seam in the top ring cuff
- Component kit, including handle attachment, bottom pad, zipper pulls, umbrella holder and socket, division strap, boot strap, and tower ring)

Shipment 3:

- Components listed in Shipment 2
- Plastic bottom base

Shipment 4:

- Bottom cuff
- Full length club dividers/screws
- Dog biscuit
- Water bottle pocket (polyester woven textile fabric) - Plastic water bottle
- Top cuff/ring assembly

Shipment 5:

- Top and bottom cuffs (nylon woven textile fabric) - Dividers/screws (sperate nylon pieces which will be attached to the plastic bottom and top ring during final assembly) - Top/ring assembly (nylon woven textile fabric) - Metal stand (attached to golf bag after importation) which, as permanent part of bag, allows the bag to stand on its own


Whether the golf bag components contained in each of the five shipments impart the essential character of a complete golf bag.


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

The HTSUS provisions under consideration are as follows:

4202 Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases, binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers; 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 sheeting of plastics, of textile materials, of vulcanized fiber or paperboard, or wholly or mainly covered with such materials or with paper.

6307 Other made up articles, including dress patterns.

Heading 4202, HTSUS, provides for sports bags. In understanding the language of the HTSUS, the Harmonized Commodity Description and Coding System Explanatory Notes may be utilized. The Explanatory Notes, although not dispositive or legally binding, provide a commentary on the scope of each heading of the HTSUS, and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). In part, Explanatory Note 42.02 (p. 661) states that:

[t]he expression "sports bags" includes articles such as golf bags, gym bags, tennis racket carrying bags, ski bags and fishing bags.

Therefore, complete golf bags are regarded as sports bags for the purposes of classification in heading 4202, HTSUS.

GRI 2(a) states that:

[a]ny reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled.

We must determine whether the golf bag components in each shipment, which together would form an incomplete golf bag, impart the essential character of a complete golf bag. In HQ 959178, dated June 24, 1996, we dealt with the classification of a golf bag body imported in an unfinished state, specifically missing a bottom, top cuff, and internal support tube. In that ruling, we stated that:

[t]his office has previously held that golf bag bodies, imported without their remaining components, do not possess the essential character of the finished article. See Headquarters Ruling Letters (HRL's) 085391, dated December 20, 1989, 957006, dated June 27, 1995, and 958915, dated February 27, 1996. The golf bag body in Scenario 1, imported into the United States without a bottom, top cuff and internal tube support, will therefore be classifiable according to its constituent materials. As the instant golf body bag is described in a manner substantially similar to those classified in the above-cited rulings, we conclude it is classifiable under subheading 6307.90.9989, HTSUSA, which is the residual provision for articles of textiles. We further note that the remaining articles do not, by themselves, possess the essential character of a finished golf bag. Accordingly, the bottom component, top cuff and internal tube support are classifiable according to their constituent materials in the appropriate headings.

With regard to the subject merchandise, Shipment 1 contains the body assembly and a shoulder strap, and each of the remaining shipments contain numerous golf bag components except for the body assembly. Based upon the reasoning in HQ 959178, it is our position that the components in each shipment do not together impart the essential character of a complete golf bag. Therefore, in each shipment, the golf bag components must be separately classifiable in the HTSUS provisions describing them. For instance, based upon the information provided, the body assembly is described in heading 6307, HTSUS.


The golf bag components in each of the five shipments do not impart the essential character of a complete golf bag. Each of the components in the shipments must be separately classifiable in the HTSUS provisions describing them.


John Durant, Director
Commercial Rulings Division

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