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September 14, 1999



TARIFF NO.: 4202.22.1500

Ms. Barbara Y. Wierbicki
Tompkins & Davidson, LLP
One Astor Plaza
1515 Broadway
New York, NY 10036

RE: The tariff classification of a handbag from China.

Dear Ms. Wierbicki:

In your letter dated August 19th, 1999, on behalf of Avon Products, Inc., you requested a tariff classification ruling for Product Profile (PP) #PP173936-B, "S.S.S. Outdoor Survival Kit Bag". The item is a double handle handbag constructed of transparent Polyvinyl Chloride (PVC) with textile trim. It measures approximately 6 1/2" in height by 7 1/2" in width by a 4" gusset. The interior of the bag is unlined and consists of a single compartment with no additional features. The top opening of the bag is secured by a center snap closure. An open pocket is featured on both the front and rear exterior of the bag.

The applicable subheading for #PP173936-B will be 4202.22.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for handbags, whether or not with shoulder strap┬with outer surface of sheeting of plastic. The rate of duty will be 18% ad valorem.

The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. ┬ž1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. We suggest that you mark the bag by means of a fabric label sewn into the side interior of the bag that reads "Made in China".

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

Your sample is being returned as requested.

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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