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NY F81028

March 23, 2000



TARIFF NO.: 4202.22.1500; 7326.20.0050

Ms. Barbara Y. Wierbicki
Tompkins & Davidson, LLP
One Astor Plaza
1515 Broadway
New York, NY 10036-8901

Dear Ms. Wierbicki:

RE: The tariff classification of a clutch purse and key fob products of China

In your letter dated December 15, 1999, you requested a tariff classification ruling. The request is on behalf of Avon Products Inc.

The sample submitted with your request is identified as PP 198302. It consists of a clutch purse and key fob put up in a retail carton with a clear plastic lid.

The clutch purse is constructed of a man-made textile body with cardboard stiffeners and a cover of embossed plastic sheeting over a split leather base. The exterior surface constituent material of the cover is the plastic sheeting. The clutch has a zipper closure that extends around three sides. It measures approximately 4 inches in width, 7 1/2 inches in height and is 1 inch when closed. The interior consists of 2 gusseted pockets, each extending the full width of the article. The gussets allow each pocket to expand and form an opening that measures approximately 1 3/4 inches in width. Between the two pockets is a separate zippered security pocket. At the rear wall of each gusseted pocket are slots for flat items such as currency and credit cards. The central compartment is designed to hold three-dimensional items in addition to the small flat goods normally carried in a clutch purse. One exterior side has a half-zippered pocket for small items and change.

The key fob consists of a tab of the same embossed plastic exterior over a cardboard and split leather base and a base metal split ring. It is commonly known as a key fob or key ring.

The applicable subheading for the clutch purse will be 4202.22.1500, Harmonized Tariff Schedule of the United States (HTS), which provides, in part, for HANDBAGS, with outer surface of sheeting of plastic. The rate of duty will be 17.6 percent ad valorem.

The applicable subheading for the key fob will be 7326.20.0050, HTS, which provides, in part, for articles of iron or steel, other. The rate of duty will be 3.9% ad valorem. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

Your samples are 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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