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NY F85659

April 28, 2000



TARIFF NO.: 4202.22.1500

Mr. Arlen T. Epstein
Tompkins & Davidson, LLP
One Astor Plaza
1515 Broadway
New York, NY 10036

RE: The tariff classification of a clutch purse with check book cover from China.

Dear Mr. Epstein:

In your letter dated April 24th, 2000, on behalf of Avon Products, Inc., you requested a tariff classification ruling.

The sample submitted with your request is identified as "Convertible Organizer Clutch on the Go", #PP 207112. The item is a clutch purse with a detachable shoulder strap packed and sold at retail with a check book cover. Pursuant to General Rule of Interpretation (GRI) 3 (b), the items are considered a set as both share the common purpose of organizing, protecting, and storing the items placed therein. Both items have and exterior surface of a fabric backed sheeting of plastic. The interior of the clutch is lined and contains three accordion compartments, each of which are separated into two compartments by a divider. The front compartment is secured by a zippered closure. The middle and rear compartments are open and contain multiple credit card slots. A front flap with a center snap closure secures the top opening of the bag.

The applicable subheading for PP 207112 will be 4202.22.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for handbags, whether or not with shoulder strapwith outer surface of sheeting of plastic. The rate of duty will be 17.6% ad valorem.

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.


Robert B. Swierupski

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