HQ 951407: Wallets; flat goods; articles of a kind normally carried inthe pocket or the handbag; of reinforced or laminated plastics;HRL 950048, HRL 950567 and HRL 950983 cited.

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                            HQ 951407

                          June 15, 1992



CLA-2 CO:R:C:T 951047 CRS

CATEGORY:  Classification

TARIFF NO.:  4202.32.1000

Steven S. Weiser, Esq.
Paul A. Horowitz, Esq.
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway, 43rd Floor
New York, NY 10036

RE:  Wallets; flat goods; articles of a kind normally carried in
the pocket or the handbag; of reinforced or laminated plastics;
HRL 950048, HRL 950567 and HRL 950983 cited.

Dear Messrs. Weiser and Horowitz:

     This is in reply to your letter of March 19, 1992, on behalf
of Michael Stevens Ltd., concerning the classification of certain
flat goods under the Harmonized Tariff Schedule of the United
States Annotated (HTSUSA).

FACTS:

     The merchandise at issue consists of five styles of wallets
(flat goods) imported from the People's Republic of China.  All
of the styles have outer pockets or compartments (a zippered
pocket on styles 25002, 25005 and 28303, and a coin purse with
snap closure on styles 25021 and 25055).  The interiors of all of
the articles contain credit card slots and bill slides, with
styles 25005, 25051 and 28303 also having zippered compartments
near the bill slide area.  Style 25002 has a zippered closure;
the remaining four styles have snap closures.

     Each style has an outer surface of polyvinyl chloride (PVC)
sheeting to which a textile fabric backing has been bonded by the
application of heat (which activates a glue that has been applied
to the textile fabric) and pressure.  Styles 25002, 25005, 25021
and 25055 have a woven fabric backing; style 28303 has a nonwoven
backing.  It is anticipated that shipments of the merchandise in
question will be entered through the ports of Newark and Los
Angeles. 

ISSUE:

     The issue presented is whether the instant wallets are "of
reinforced or laminated plastics" such that they are classifiable
in subheading 4202.32.1000, HTSUSA.

LAW AND ANALYSIS:

     Heading 4202, HTSUSA, provides, inter alia, for wallets. 
The instant merchandise consists of five styles of wallets.  The
articles in question are provided for eo nomine in heading 4202
and are therefore classifiable accordingly.

     Subheading 4202.32, HTSUSA, provides for articles of a kind
normally carried in the pocket or handbag with an outer surface
of plastic sheeting or of textile materials.  The Explanatory
Notes (EN), while not legally binding, are considered by Customs
to constitute the official interpretation of the Harmonized
System at the international level.  The Subheading Explanatory
Note to EN 42.02 states that the provision for articles of a kind
normally carried in the pocket or the handbag includes wallets.

     Additional U.S. Note 2, Chapter 42, HTSUSA, provides that
for the purposes of classifying articles in subheading 4202.32:

     [A]rticles of textile fabric impregnated, coated,
     covered or laminated with plastics (whether compact or
     cellular) shall be regarded as having an outer surface
     of textile material or of plastic sheeting, depending
     on whether and the extent to which the textile material
     or the plastic constituent makes up the exterior
     surface of the article.

Plastics makes up virtually all, if not the entire surface of the
wallets in question.  Accordingly, the five styles of wallets at
issue, all of which have an outer surface of plastics, are
classifiable in subheading 4202.32, HTSUSA.

     Subheading 4202.32.1000, HTSUSA, provides for articles of a
kind normally carried in the pocket or handbag, i.e., flat goods,
with an outer surface of reinforced plastics.  Customs has held
that flat goods of similar construction to the merchandise at
issue was "of reinforced or laminated plastics" for the purposes
of subheading 4202.32.1000, HTSUSA.  Headquarters Ruling Letter
(HRL) 950048 and HRL 950567 dated March 2, 1992; HRL 950983 dated
June 15, 1992.

HOLDING:

     The five styles of merchandise at issue are classifiable in
subheading 4202.32.1000, HTSUSA, under the provision for articles
of a kind normally carried in the pocket or in the handbag:  with
outer surface of plastic sheeting or of textile materials:  with
outer surface of plastic sheeting:  of reinforced or laminated
plastics.  They are dutiable at the rate of 12.1 per kilogram
plus 4.6 percent ad valorem.

                         Sincerely,





                         John Durant, Director