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July 15, 1999

CLA-2-42:RR:NC:341:E81544

CATEGORY: CLASSIFICATION

TARIFF NO.: 4202.21.6000; 4203.30.0000

Mr. Arthur W. Bodek
Graham & James LLP
885 Third Avenue, 21st Floor
New York, NY 10022

RE: The tariff classification of a leather handbag and belt from China.

Dear Mr. Bodek:

In your letter dated April 28th, 1999, on behalf of Liz Claiborne, Inc., you requested a tariff classification ruling for a leather handbag and belt from China.

The sample submitted with your request is identified as "Leather/Bonded Leather Belt Bag," style #FE947210, that consists of a ladies' belt and convertible shoulder bag. The bag may be carried on the shoulder or at the waist with the belt. The belt is manufactured of pig suede with polyurethane backing and is fastened by means a gold tone buckle. The surface has a patent leather luster. The convertible shoulder bag is manufactured of a front panel of printed leather, which simulates a leopard skin, and a back panel of polyurethane coated composition leather. The shoulder strap is removable. The bag has a belt loop sewn to the rear of the back panel. The essential character of the bag is imparted by the printed leather front panel.

The ladies' belt and bag are each of a kind normally offered for sale in separate parts. General Rule of Interpretation 3 (b) Explanatory Note (IX) provides that for goods to be considered a composite, they must together form a whole which would not normally be offered for sale in separate parts. Therefore, the ladies' belt and bag are not considered to be a composite good for tariff purposes.

The applicable subheading for the shoulder bag will be 4202.21.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for handbags, whether or not with shoulder strap, including those without handle, with outer surface of leather, of composition leather or of patent leather, other, valued not over $20 each. The rate of duty will be 10% ad valorem.

The applicable subheading for the belt will be 4203.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for articles of apparel and clothing accessories, of leather or of composition leather, belts and bandoliers with or without buckles. The rate of duty will be 2.7% 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.

Sincerely,

Robert B. Swierupski
Director,

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