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NY N008445

April 16, 2007



TARIFF NO.: 4202.92.4500, 6302.60.0020

Annelori Roder
Crocs, Inc.
6328 Monarch Park Place
Niwot, CO 80503

RE: The tariff classification of travel bag and towel from China

Dear Ms. Roder:

In your letter dated March 9, 2007, you requested a classification ruling. Your samples will be returned as requested.

The sample submitted is a travel bag with a towel. The bag is constructed of 100% polyvinyl chloride (PVC) sheeting plastic. The bag features a three-sided textile zipper closure with a short webbed carrying strap. The interior of the bag is fitted with two small audio speakers and an insulated electronic cable. The bag measures approximately 9” (W) X 6.5” (H) X 4” (D).

The applicable subheading for the bag will be 4202.92.4500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for travel, sports and similar bags, with outer surface of plastic sheeting, other. The duty rate will be 20 percent ad valorem.

The beach towel is made from 100 percent cotton woven terry fabric. The front portion of the towel is sheared and printed. The back has uncut loops. All of the edges are hemmed. The towel measures approximately 20” x 43.”

The applicable subheading for the beach towel will be 6302.60.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for bed linen, table linen, toilet linen and kitchen linen: toilet linen, of terry toweling or similar terry fabrics, of cotton... other. The duty rate will be 9.1 percent ad valorem.

You have requested that the beach bag and towel be classified as a set under subheading 6307.90.8940, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other made up articles, including dress patterns: other: other: other: surgical towels; cotton towels of pile or tufted construction; pillow shells, of cotton; shells for quilts, eiderdowns, comforters and similar articles of cotton... cotton towels of pile or tufted construction. The bag is wholly of polyvinyl chloride (PVC) sheeting of plastic and is of the kind similar to the eo nominee travel bags of subheading 4202.92. The bag is more specifically provided for in the provision for travel bags.

Although sold as a set, the beach bag and towel are not classifiable as a set because they are not designed to meet a particular need or carry out a specific activity. The polyvinyl chloride bag, which is a separate article of commerce and more than just a packing container, has a different use than the towel. Consequently, each item is classifiable separately under its appropriate heading.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

HTS 6302.60.0020 falls within textile category 363. With the exception of certain products of China, quota/visa requirements are no longer applicable for merchandise which is the product of World Trade Organization (WTO) member countries. The textile category number above applies to merchandise produced in non-WTO member-countries. Quota and visa requirements are the result of international agreements that are subject to frequent renegotiations and changes. To obtain the most current information on quota and visa requirements applicable to this merchandise, we suggest you check, close to the time of shipment, the “Textile Status Report for Absolute Quotas” which is available on our web site at www.cbp.gov. For current information regarding possible textile safeguard actions on goods from China and related issues, we refer you to the web site of the Office of Textiles and Apparel of the Department of Commerce at otexa.ita.doc.gov.

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 Vikki Lazaro at 646-733-3041.


Robert B. Swierupski

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