Customs Proposes to Revoke Certain Travel Goods Rulings

In Binding Ruling Lettes NY 868779 and NY 871870, from 1991 and 1992, CBP classified two textile money belts in heading 4202 of the Harmonized Tariff Schedule of the United States (HTSUS), specifically in subheading 4202.32.95, HTSUS, as articles of a kind normally carried in the pocket or in the handbag, with an outer surface of textile materials. CBP has reviewed NY 868779 and NY 871870 and has determined the ruling letters to be in error. It is now CBP’s position that the subject money belts are properly classified in heading 4202, HTSUS, specifically in subheadings 4202.92.15 and 4202.92.31, HTSUS, as travel, sports and similar bags, with an outer surface of textile materials.

CBP is proposing to revoke NY 868779, modify NY 871870, and revoke any treatment previously accorded by CBP to substantially identical transactions.

Comments must be received on or before December 27, 2017.

BACKGROUND

In NY 868779 and 871870, CBP concluded that money belts, measuring 17.5 inches by 4.75 inches and 16 inches by 4.5 inches, respectively, were “of a kind” normally carried in the pocket or a handbag. This conclusion, CBP now believes, was incorrect. These money belts are not designed to be carried inside any other bag or container; they are designed to fasten around the waist precisely so that they can be transported by themselves, without the need for any other kind of container. Placing either money belt inside a pocket or handbag would defeat the entire purpose of the article, which is to provide secure, easy and unobstructed access to money and other small valuables. Taking the money belt out of the pocket or purse in order to remove the valuables stored within would be an extra, unnecessary step. Additionally, at a width of 17 and 16 inches, both money belts are too large to fit inside most handbags and pockets.

THE FULL TEXT is available HERE, beginning on page 25.