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July 26, 1999

CLA-2-42:RR:NC:341:E83347

CATEGORY: CLASSIFICATION

TARIFF NO.: 4202.22.1500; 8470.10.0040

Ms. Barbara Y. Wierbicki
One Astor Plaza
1515 Broadway
New York, NY 10036

RE: The tariff classification of a clutch purse from China.

Dear Ms. Wierbicki:

In your letter dated June 14th, 1999, on behalf of Avon Products, Inc., you requested a tariff classification ruling for a clutch purse from China.

The sample submitted with your request, Product Profile (PP) #194829, "August Conference Money Holder," is a tri-fold clutch purse that has an overall exterior measuring 7 1/2" x 5 1/8" x 1 1/4¬Ē when closed and empty. The exterior surface is of a cellular plastic sheeting that is embossed to simulate a leather grain. The exterior surface is backed with a brushed woven fabric that is present to impart a soft "hand" or feel to the imitation leather exterior as well as to reinforce the plastic sheeting. A front flap with a center snap closure secures the clutch. The interior upper portion of the clutch has multiple credit card slots, two billfold sections and a solar powered credit card calculator that is held in place with hook and loop tapes. The interior lower portion is the main body of the clutch and consists of three gusseted storage sections, each having an expanding width of one inch. A matching removable checkbook cover is inserted into a slot in front of the gusseted storage sections. The rear exterior of the clutch has a zippered pocket suitable for coins.

Product Profile (PP) 194829, "August Conference Money Holder," is chiefly designed and used to contain articles other than those flat goods normally carried in a wallet or billfold. The overall size and configuration is not of a kind normally carried in a handbag or pocket; it is of a kind normally carried as a clutch purse in the hand.

The applicable subheading for the clutch purse portion of Product Profile (PP) 194829, "August Conference Money Holder," will be 4202.22.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for handbags, whether or not with shoulder strap, including those without handle¬with outer surface of sheeting of plastic. The rate of duty will be 18% ad valorem.

The applicable subheading for the calculator portion of Product Profile (PP) 194829, "August Conference Money Holder," will be 8470.10.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for electronic calculators capable of operation without an external source of electric power and pocket-size data recording, reproducing and displaying machines with calculating functions¬display only. The rate of duty will be free.

Your sample is being returned as requested.

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.

Sincerely,

Robert B. Swierupski
Director,

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