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March 16, 1999

CLA-2-42:RR:NC:3:341 D86662


TARIFF NO.:4202.22.1500

Mr. Arlen T. Epstein
Tompkins & Davidson,LLP
One Astor Place
1515 Broadway
New York, N.Y. 10036-8901

RE: The tariff classification of a handbag and clutch from China

Dear Mr. Epstein:

In your letter dated January 11, 1999, you requested a tariff classification ruling. The request is on behalf of Avon Products, Inc.

You have submitted samples of a ladies shoulder bag and clutch which are identified as Product Profile (PP) 187376. Each article is manufactured of a sheeting of plastic consisting of an exterior surface of plastic sheeting and a woven fabric backing material. The shoulder bag and clutch are of a kind which normally would be sold in separate parts. The samples are being returned as requested.

The shoulder bag is identified by means of a sewn in label as style P 1120-1C. It has an overall measurement of 14 1/2" x 10" x 4 1/2". The top is closed by means of a center snap and each end gusset has a snap fastener which secures the gussets in a closed position if desired. The interior is textile lined and has a center zippered compartment which divides the interior into three sections. There is a zippered utility pocket, which measures approximately 7" wide by 6" deep, sewn into an interior wall. The bag has a single open pocket on the exterior front.

The clutch is not identified by a separate style number. It has an overall measurement of 7 1/2" in width by 4" in height by 1 1/2" when empty. It has a snap flap which secures the contents. The interior is fitted with six credit card slots, one bill fold section and two gusseted sections which have the same width as the overall clutch. One gazette section expands to a depth of 2 1/2". The second gusseted section expands 2 1/2“, has a center divider and a zipper closure. The interior of the flap has a slot for identification cards and a clear view window which is intended to contain either an identification card or a mirror. The exterior rear of the clutch has a zippered pocket, approximately 6” long by 2 1/4" deep and a single gusseted end panel. There is a matching checkbook cover inserted into the clutch.

The applicable subheading for style P 1120-1C, shoulder bag, will be 4202.22.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for Handbags, with outer surface of sheeting of plastic. The rate of duty will be 18 percent ad valorem.

The clutch bag is similar to Avon Products, Inc., Product Profile 155985 which was the subject of HQ 960180, August 12, 1997. In that decision Customs found that the clutch is fitted to hold items such as credit cards, paper currency, photos as well as other dimensional items carried in a handbag. Its central compartments’ gusseted pockets provide a generic carrying capacity for a variety of loose personal effects (e.g. lipstick, pens, a set of keys, etc.) The article was found to be of a kind similar to a clutch purse variety of handbag.

The applicable subheading for the clutch portion of PP 187376 is HTS 4202.22.1500, HTS, which provides for Handbags, with outer surface of sheeting of plastic. The rate of duty is 18 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Kevin Gorman at 212-637-7091.


Robert B. Swierupski

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