Tariff classification of accessories from China; articles of a kind normally carried in the pocket or in the handbag; wallet.
Active· CBP ruling HQ 957360· Issued 1995-01-30
Ruling text
HQ 957360
January 30, 1995
CLA-2 CO:R:C:T 957360 ch
CATEGORY: Classification
TARIFF NO.: 4202.32.1000
Marty Langtry
Tower Group International, Inc.
5420 W. 104th Street
Los Angeles, California 90045-6069
RE: Tariff classification of accessories from China;
articles of a kind normally carried in the pocket or in
the handbag; wallet.
Dear Mr. Langtry:
This is in response to your letter of October 13, 1994, on
behalf of Tower Group International, Inc., requesting tariff
classification under the Harmonized Tariff Schedule of the United
States (HTSUS) for three articles described as fold-over wallets.
Please be advised that we are retaining the samples in order to
facilitate uniformity of classification in this area.
FACTS:
The submitted samples, styles 30500, 30501 and 36422, are
tri-fold accessories with detachable shoulder straps. They
measure approximately 7 1/2 inches by 4 1/2 inches in their
closed position. These items possess an outer surface of plastic
sheeting which has been laminated to a textile material backing.
The articles feature interior slots for credit and identification
cards, pockets for coins and paper currency, a checkbook holder
and pen loops. The exterior includes a full width gusseted
utility pocket secured by means of hook and loop fastener
material.
ISSUE:
Whether the subject merchandise is classifiable in
subheading 4202.22, HTSUS, which provides for handbags; or
subheading 4202.32, HTSUS, which provides for articles of a kind
normally carried in the pocket or in the handbag?
LAW AND ANALYSIS:
Heading 4202, HTSUS, provides inter alia for handbags and
wallets. Subheading 4202.22, HTSUS, encompasses handbags;
subheading 4202.32, HTSUS, describes articles of a kind normally
carried in the pocket or handbag. The subheading Explanatory
Note to heading 4202, at page 613, indicates that wallets are
classified within subheading 4202.32. Pursuant to General Rule
of Interpretation 6, classification of goods at the subheading
level shall be effected mutatis mutandis with General Rules of
Interpretation 1 through 5.
The term "wallet" is not defined in the HTSUS or in the
applicable Explanatory Note to heading 4202, HTSUS. However, we
note the following definitions of the term "wallet" from
lexicographic sources:
Essential Terms of Fashion: A Collection of
Definitions, Charlotte M. Calasibetta, Fairchild
Publications, 1986: An item used to carry paper money,
credit cards, photographs and sometimes with a change
purse or space for a check book or pad.
The Fashion Dictionary, Mary Brooks Picken, Funk &
Wagnalls, 1973: 1. Flat purse or pocketbook, for
carrying either paper money or coins.
Webster's New Collegiate Dictionary, G. & C. Merriam
Co., 1977: 1. a bag for carrying miscellaneous
articles while traveling; 2 a: billfold b: a
pocketbook with compartments for change, photographs,
cards, and keys.
Webster's New World Dictionary, Third College Edition,
Simon & Schuster, Inc., 1988: 1. [Archaic] a
knapsack; 2. a flat pocketbook, as of leather, with
compartments for paper money, cards, etc.; billfold.
We also recognize that the term "handbag" has been defined
as follows:
Essential Terms of Fashion: A Collection of
Definitions: Accessory carried primarily by women and
girls to hold such items as money, credit cards, and
cosmetics.
The Fashion Dictionary: Soft or rigid bag carried in
hand or on arm. Size, shape, handle, etc., depend on
fashion. Used by women as container for money and
pocket-sized accessories.
Webster's New Collegiate Dictionary: 1. traveling bag;
2. a woman's bag held in the hand or hung from a
shoulder strap and used for carrying small personal
articles and money.
Webster's New World Dictionary: A bag, usually of
leather or cloth, held in the hand or hung by a strap
from the arm or shoulder and used, by women, to carry
money, keys, and personal effects.
The submitted samples possess attributes of both wallets and
handbags. For example, they feature credit card slots, pockets
for paper currency/coins and identification card windows, which
are associated with wallets. On the other hand, these articles
possess a shoulder strap and an exterior utility pocket. As the
samples are described by two subheadings within heading 4202,
HTSUS, we must resort to General Rule of Interpretation 3, in
conjunction with General Rule of Interpretation 6, to determine
their proper classification.
Although the presence of a carrying strap permits the
articles to be worn on the shoulder in a manner consistent with a
handbag, we conclude that a strap in and of itself should not
affect their classification. In this regard, we note that the
provision for handbags specifies that handbags may or may not
have a shoulder strap. Moreover, in this instance the straps are
detachable, suggesting a dual use for the merchandise as articles
to be carried in a handbag. It should also be noted that as a
class of merchandise wallets are normally carried in the pocket
or in the handbag, notwithstanding the fact that it has recently
become popular to carry these items by means of a shoulder strap.
Furthermore, we are of the opinion that the determinative
feature of a handbag is its ability to hold several objects not
associated with a wallet. In this instance, the articles are
fitted to hold objects associated with a wallet as they are flat
and possess slots and pockets to hold credit cards,
identification cards, paper currency and coins. In addition,
they are of a size suitable for carrying in a handbag. We note
that the addition of the exterior pocket is a step in the
direction of a handbag, as the article begins to take the
character of a carry-all container. However, the exterior
pockets are relatively flat and do not possess sufficient
capacity to hold small personal effects which are typically
carried in the handbag (e.g. hairbrush, cosmetics, keys on a
chain). Consequently, in this instance we conclude that the
merchandise is most specifically described by the provision for
articles of a kind normally carried in the pocket or in the
handbag.
HOLDING:
The subject merchandise is classifiable under subheading
4202.32.1000, HTSUS, which provides for articles of a kind
normally carried in the pocket or in the handbag: with outer
surface of sheeting of plastic: or reinforced or laminated
plastics. The applicable rate of duty is 12.1 cents/kilogram +
4.6 percent ad valorem.
Sincerely,
John Durant, Director
Commercial Rulings Division
Source: rulings.cbp.gov — ruling 957360, retrieved 2026-10-12T05:29:57Z, republished verbatim. This digest is informational; only CBP issues binding rulings.