N322591

N322591 November 19, 2021 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 4202.92.0807; 9903.88.03 Joseph J. Kenny Geodis USA Inc. One CVS Drive Woonsocket, RI 02895 RE: The tariff classification of an insulated cooler bag with a detachable compartment from China Dear Mr. Kenny: In your letter dated November 2, 2021, you requested a tariff classification ruling on behalf of your client, CVS Pharmacy, Inc. You have submitted images in lieu of a sample. The article at issue, which you referred to as the “Dual Cooler and Tote, Item number 332612,” is an insulated cooler bag with a detachable mesh compartment. In your submission, you stated that the cooler bag is constructed with an outer surface of polyester textile material. It provides storage, protection, organization and portability to food or beverage during travel. It is also designed to maintain the temperature of food or beverages. Based on the submitted images, the article has a main compartment that is lined with plastic sheeting. There is a layer of foam plastic between the lining and the textile outer layer. The cooler bag features a zippered closure and two handles. You did not submit measurements to this office. The detachable compartment is constructed of mesh textile. The bottom of the mesh compartment features a zipper that can be attached on top of the cooler bag. It does not have handles and is not functional on its own. The insulated cooler bag and the mesh compartment form a composite good, General Rule of Interpretation 3(b) of the Harmonized Tariff Schedule of the United States (HTSUS) noted. The two items are adapted to each in that the mesh compartment slips over the straps of the cooler bag when it is in use. The bottom of the mesh compartment is sized to correspond with the top of the cooler bag allowing it to serve as the base to the mesh compartment. The bottom of the mesh compartment also zips to the top of the cooler bag to secure it in place. The essential character of the composite good is imparted by the cooler bag as it is the primary component. It is the component that prompts the consumer to purchase the article. The mesh compartment is an optional component and will only be used as needed. The applicable subheading for the insulated cooler bag will be 4202.92.0807, HTSUS, which provides for insulated food and beverage bags, with outer surface of sheeting of plastic or of textile materials, with outer surface of textile materials, other, of man-made textiles. The duty rate will be 7 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 4202.92.0807, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 4202.92.0807, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively. 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 the World Wide Web at https://hts.usitc.gov/current. 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 vikki.lazaro@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division