LAZARO, VIKKI Good morning, everybody.
Can you hear me now?
LAZARO, VIKKI I'm having a little bit of a sticky finger here.
LAZARO, VIKKI Hey everybody, I'm here.
LAZARO, VIKKI So again, so I said.
LAZARO, VIKKI You know, articles in the first half
of the heading are limited by material.
LAZARO, VIKKI Articles in the first half
of the heading are not limited by material.
However, plating material is a little tricky.
LAZARO, VIKKI Uh, because where does this go?
So sounds like plating material will be OK in the first half
of the heading where the trunks and the suitcases are.
However, you know, cause it's in the before the semi colon.
LAZARO, VIKKI But before we get to the heading level,
when you're classifying something, you always look at the chapter notes first.
First, first chapter notes, then headings.
There's a particular order to things, and you see
at the bottom I've highlighted something.
LAZARO, VIKKI Touch specific chapter note in had in Chapter 4202,
so I'm going to highlight that a little better here
and it's saying Chapter Note 3 gives us in addition to the provisions
of Note 2, heading 4202 does not cover articles of plating material,
so this sort of this chapter note Trump's.
LAZARO, VIKKI What we see in at the heading level chapter notes
first heading level second.
So it's saying at the chapter level that plating material is excluded
from heading 4202, so plating material is an exception.
It's not permitted in the first half of the heading and it's not permitted
in the second half of the heading.
And again, if you do have an article that you think is plating material
and you're not sure Charlene Miller would be the person
to explain the rules on whether or not it's plating material for the purposes
of 4202, I just want to be clear.
LAZARO, VIKKI That articles of plating material are not in 4202.
LAZARO, VIKKI Again, they're not permitted in either section.
First half, second half, because we have this chapter note,
which is more important than is is is more is primary to what it says
in the heading.
LAZARO, VIKKI Another question we get or another thing
that's confusing to people sometimes is, is it true
that all plastic is the same?
Well, it depends on your point of view.
LAZARO, VIKKI For the point of view of heading 42 or two,
we have molded plastic and we have plastic sheeting
and the names sort of suggests pretty clearly the difference.
Molded plastic is when plastic is molded to shape the article.
The finished article is molded to shape.
So imagine molten hot lava like plastic being poured in a liquid form
into a mold similar to the one on the eat.
LAZARO, VIKKI Of the left side and then drying and solidifying
and becoming the shape from that molten hot plastic material
that would be molded to shape.
LAZARO, VIKKI As the name would suggest,
and then we have plastic sheeting again as the name would suggest,
it's plastic and sheet form and for the purposes of 42 or two,
it doesn't really matter how it became a sheet.
You know it could be a you know like on this picture on the right
that you see it's in roles.
So you could take that role, apply it to something you could cut
the plastic sheeting.
LAZARO, VIKKI You, uh, you know, bind it together to make
to make the product.
It's still of plastic sheeting.
LAZARO, VIKKI Like in the construction, it's out.
We're looking to see now, OK, it's multiple plastic is this is the base
with a cover of the material that's permitted.
So that would be the first scenario where molded plastic is permitted.
LAZARO, VIKKI And then, of course, the second is, is it one of the articles
in the first half of the heading, is it a trunk?
Is it a binocular case or is it similar to if it's, if it falls
in the first half of the heading there isn't that same limit on the materials?
Multiple plastic would be permitted in the first half of the heading.
So there's those two scenarios where.
LAZARO, VIKKI It can be included at molded plastic.
LAZARO, VIKKI So then another thing that causes a lot
of confusion is nonwoven polypropylene.
LAZARO, VIKKI Umm, you know, is it a plastic?
Because you know the word polypropylene.
It sounds like it's plastic, you know, so a lot of times people are confused.
They see this word, polypropylene and they assume, oh, it must be plastic.
LAZARO, VIKKI Or and it it looks like cheating.
You know it's it's.
It's like you see in this photo.
It's in sheet form.
So is this plastic sheeting?
LAZARO, VIKKI Is it?
Is it?
So let's see.
No, it's not Putnam.
Polypropylene.
Nonwoven.
Polypropylene is a man made textile material.
So again, it's still permitted in the second half of the heading
because it's a textile material man made, that's certainly allowable.
But you do at the subheading level, you do have to make that distinction
between polypropylene and man-made textile because at the subheading level,
they're going to be classified differently.
LAZARO, VIKKI So, cannonvale polypropylene ever be classified
as plastic sheeting?
Tricky.
It's a little little.
Well, I gave you the answer.
Yes, it can.
LAZARO, VIKKI Sorry about that.
The little my mouse is a little touchy today.
LAZARO, VIKKI Yes, it can be.
It can.
So can nonvalue nonwoven polypropylene ever be classified as plastic sheeting?
Yes.
LAZARO, VIKKI So you see here we have at a sub at the subheading level
with outer surface of plastic sheeting or of textile materials.
So there is a distinction.
Keep that in mind.
LAZARO, VIKKI But if you have a textile material nonwoven,
polypropylene, or really any textile material that is then coded on one side.
LAZARO, VIKKI And that outer surface of the finished article
is the plastic sheeting.
So in this case, if if we made a 42 or two article from this this material
that I'm showing you here you have one side
with the the white colored textile side and then you have
the plastic sheeting orange side if we use this to make.
LAZARO, VIKKI An orange handbag, meaning that plastic sheeting
is the outer surface.
This would be classified as outer surface plastic sheeting.
So we're looking at the finished article.
And this is regardless of where this particular coded fabric
would be classified on its own if it came in bulk.
LAZARO, VIKKI Umm outer surface plastic sheeting.
So when you have coated textiles.
LAZARO, VIKKI You want to be really clear number one,
that plastic sheeting is potentially in play and #2 which side?
LAZARO, VIKKI Of the coated.
LAZARO, VIKKI Fabric is making up the outer surface of the finished item.
LAZARO, VIKKI And then another thing that causes some confusion is wristlets.
LAZARO, VIKKI And.
LAZARO, VIKKI You know, we get.
Oh, is it a wallet?
Is it a handbag?
You know, it has a strap.
What do we do?
Get a lot of these type of questions and a wristlet.
LAZARO, VIKKI Is not.
LAZARO, VIKKI It is not a term that really has any significance
within heading 4202.
LAZARO, VIKKI A wristlet is more of a retail term for.
LAZARO, VIKKI So it could have.
It could be a a wrist strap attached to a handbag.
It could be a wrist strap attached to a wallet.
It could be a risk drop attached to.
Or you could.
I've seen wrist straps attached to spectacle cases, so the fact
that it has this wristlet term in the marketing or the fact
that it has a risk strap doesn't automatically change the classification.
LAZARO, VIKKI So it comes up most often with wallet versus handbag.
LAZARO, VIKKI And often there are even detachable.
LAZARO, VIKKI So this does not change the classification.
This is not what we're looking for.
We're not looking for a restrap when we're making these determinations.
LAZARO, VIKKI Umm.
In fact, at the subheading level.
LAZARO, VIKKI Where we have the subheading for handbags,
it says whether or not with.
LAZARO, VIKKI Says whether or not with shoulder strap, including those
without a handle.
So right here at the sub heading level, it's letting us know.
Strap no strap, doesn't matter.
Doesn't matter.
So we're not looking at whether or not it has a wrist drop.
And in terms of.
LAZARO, VIKKI The language of the word wristlet doesn't mean anything
for tariff purposes.
It's more of a like I said, a marketing or a retail term.
LAZARO, VIKKI So what is the wallet?
What is the difference between a wallet versus a handbag?
How do we tell the difference if it's not about the wrist strap?
LAZARO, VIKKI Well, here we have two wallets.
LAZARO, VIKKI One does have a strap, the other one does not.
What we're seeing here is that they are lacking the storage
for three dimensional objects.
LAZARO, VIKKI They are intended for flat goods such as paper.
Uh, your identification.
Even the coin would be considered a flat good.
A small coin purse or small coin compartment rather is permitted
with or without a stroller strap.
So really the difference between a wallet and a handbag is we're looking
for space for three dimensional objects.
LAZARO, VIKKI And wallets are classified as articles
of a kind normally carried in the pocket or the sub or in the handbag
at the subheading level.
LAZARO, VIKKI And again, with or without a strap,
if it doesn't have the space for the three.
LAZARO, VIKKI It's not going to be considered a handbag.
It's going to be considered a wallet.
LAZARO, VIKKI So here we have the inside of a handbag you're seeing.
It's like that open generic storage space for three dimensional objects.
While it append lip gloss, we have here another one here.
Handbags have that open general generic space
for various smaller 3 dimensional objects.
LAZARO, VIKKI Here we see at the, so this one would be a handbag.
We're seeing space for three dimensional objects.
LAZARO, VIKKI This is the kind that really gets people confused
because it's kind of right in what you'd call that Gray area.
You're seeing some features of a wallet with the the slots for credit cards
or identification, and then it has minimal space
for three dimensional objects.
LAZARO, VIKKI So a handbag can have some slots.
A handbag can have some what quote UN quote wallet type features
like the slots for credit cards.
LAZARO, VIKKI But this one does have.
LAZARO, VIKKI It it's minimal.
It's not, you know, the biggest handbag I've ever seen, but it does have space
for those three dimensional objects.
So when you're looking for the line in the sand,
this one I would do as a handbag, you know, it's got that space
for the three dimensional objects.
LAZARO, VIKKI Or at least one or two three dimensional objects.
LAZARO, VIKKI OK.
And now the biggest question in 4202 was always handbag versus tote bag
and again, tote bags are considered travel bags,
that's where they're classified.
Keep that in mind as we go along.
So how do we determine handbag versus topic?
LAZARO, VIKKI Well, we have a lot of it's common misconceptions
in this conversation, so let's go over a couple of them.
LAZARO, VIKKI I've heard if it has a zipper, it's a handbag, right?
LAZARO, VIKKI What about aligning if it has a lining?
It's definitely a handbag.
LAZARO, VIKKI I'm busy.
I need a lot of stuff everyday, so my big bag is my handbag.
LAZARO, VIKKI All shoulder bags are sandbagged, right?
LAZARO, VIKKI Might want to lower your volume a little bit.
LAZARO, VIKKI Dot zippers.
It's all about the space, about the space.
LAZARO, VIKKI Not linings.
LAZARO, VIKKI It's all about the space, about the space, not pockets.
It's all about the space, about the space, about the space, space, space,
space, space.
LAZARO, VIKKI OK, I hope I didn't hurt your ears,
but it's all about the space.
That's what we're talking about.
LAZARO, VIKKI Not outer space.
LAZARO, VIKKI The interior space of the bag.
That's what we're looking at.
LAZARO, VIKKI I'm glad I didn't hurt your ears.
I see your little thumbs up, so I'm glad I didn't hurt you.
So with handbag versus Toad, it's all about the space.
Cause say the same thing about the wallets versus the handbag.
It's about that interior space.
LAZARO, VIKKI So what are we looking for?
LAZARO, VIKKI So here's I love this photo.
This is one of my favorite photos.
If you come to my webinars every year, you may have already seen it,
but I love it because we have.
If I described these two bags to you without the dimensions,
they're going to sound identical.
Same handles, same material, same shape.
We're gonna assume for argument's purpose at the interior is the same,
lining the same number of pockets.
LAZARO, VIKKI But because one is larger.
LAZARO, VIKKI And it's gonna have more space.
One could be a a tote bag and the other could be a handbag.
LAZARO, VIKKI So keep that in mind, especially if you guys have a lot
of products where they're all similar and they're all different sizes.
LAZARO, VIKKI You can't just look at the the description.
You have to look at the dimensions as well.
The interior storage capacity.
LAZARO, VIKKI So handbags are designed in size
to contain small articles commonly carried on a daily basis,
keys, while it lipstick compact.
And remember those are three dimensional objects just to reinforce that.
LAZARO, VIKKI So these are the kind of things that would be
what you would be able to fit in a in a in a handbag
that would be a handbag for tariff purposes.
LAZARO, VIKKI We have the brush, a lip gloss and a little clip.
Do you smaller articles for the things that you might bring, you know,
just to go out to dinner or you're gonna be leaving the house
just for a few hours?
LAZARO, VIKKI Tote bags.
LAZARO, VIKKI Are classified as travel bags.
LAZARO, VIKKI My mouse is a little slippery today, sorry about that.
Designed and sized to contain larger personal effects associated with travel.
If you've ever asked for a ruling for me,
you've definitely gotten that language.
We're looking at books, clothing, shoes, food, beverages, things of that nature.
So if you have a bag and it's the contents, it has this type of contents
that a water bottle, a book, you know, other little pouches
to organize the thing better.
LAZARO, VIKKI Most likely you have a tote bag.
You I don't see too many handbags that are gonna fit this amount of stuff.
LAZARO, VIKKI Or this type of stuff.
OK, this is the.
This is the question we get the most.
LAZARO, VIKKI What about the 12 inch rule?
Well, what about the 12 inch roll?
OK, it's the 12 inch quote UN quote.
Rule is not a rule, it's a guideline and it's a guideline that makes a lot
of sense though, because it is all about the space.
LAZARO, VIKKI And once you have a bag that's having one side,
at least one side about 12 inches, that is around the point
where you're gonna have space for the larger items.
So it's a guideline.
It's not a rule, it's there to help you understand
where the Gray area starts so it.
But it is all about the space.
It's not a rule, but it it is a guidance that makes a lot of a lot of sense.
I can't say this enough because when you're starting to see.
LAZARO, VIKKI 1213 inches on one side.
That's around the point where you're starting to be able
to fit those larger items associated with travel,
so obviously keep it in mind.
But you know, if you have a bag and it's, you know, 12.1 inches on,
you have to look at the other features, the opening,
the storage capacity is something about the design limiting
or extending the use.
So it's all about the space.
LAZARO, VIKKI OK, so now I just wanna go over
and just set the record straight about some layman's terms
that are not applicable in heading 4202.
LAZARO, VIKKI First one, we just went over is wristlets.
That's just means that the article has a wrist strap,
doesn't change the classification or determine it one way or the other.
LAZARO, VIKKI But then we also have pocketbooks.
You know, you could say somebody.
Ohh, could you hand me my pop, my pocketbook?
Go get me my pocketbook.
You know, they might hand you an evening bag.
They may hand you.
You know, this giant tote bag that could fit a small child, you know?
LAZARO, VIKKI It's not.
It's just a layman's terms for the bag.
I chose to bring with me today.
It doesn't have a a tariff significance, pocketbook.
So forget about that one.
LAZARO, VIKKI And then purse again in common vernacular purse and.
LAZARO, VIKKI Purse.
And I'm gonna answer any questions at the end, guys.
So just let just bear with me.
I might also answer your question.
LAZARO, VIKKI As we go, so purrs and pocketbook are in.
LAZARO, VIKKI You know, common vernacular, synonymous
with the bag I chose to carry with me today, but for Tara purposes,
purse and handbag are absolutely not synonymous.
LAZARO, VIKKI For the purposes of 4202, purses refers to coin purses,
not to handbags or tote bags or anything like that.
So for tariff purposes, purses there, there is a classification for purses
and heading 4202, but it's for coin purses.
LAZARO, VIKKI And those, incidentally, are classified as articles
of a kind normally carried in the pocket of or in the handbag,
along with wallets.
LAZARO, VIKKI And then the final layman's term that I want
to talk about is cosmetic cases.
We get a lot of classification questions and it's just a lot of questions
in general about cosmetic cases.
Well, cosmetic case is another one of these layman's terms
that doesn't have significance in heading 4202.
LAZARO, VIKKI Cosmetic cases could mean many things
and it means different things to different people.
LAZARO, VIKKI So these are three different bags.
Step.
Somebody might refer to as a cosmetic case.
LAZARO, VIKKI In real life.
LAZARO, VIKKI But it's really not because you have numerous pockets,
but they're all generic pockets.
You see, you just have a mesh pocket, uh, a plastic sheeting pocket.
It has lots of compartments, but the compartments aren't dedicated
to anything precise.
And and also it's for toiletry articles, not for cosmetics.
Anyway.
So this would not be considered a boundary case for tower purposes.
These these two types would be travel, sport and similar and.
LAZARO, VIKKI These are both the type of case that's usually.
LAZARO, VIKKI Then going to be carried in a larger item,
for example a tote bag or a suitcase.
So these are the type of things they're travel articles, but they're used
to organize your belongings, generally inside a larger travel.
LAZARO, VIKKI But larger travel case, again like a suitcase or tote bag.
LAZARO, VIKKI And then another question
we get sometimes is the difference
between a handbag and a generic pouch.
Now if you look at these two here, they're both the same color.
LAZARO, VIKKI They're probably both made of plastic sheeting.
LAZARO, VIKKI They both have a zipper at the top there probably
about the same size.
One has a wrist strap, one has kind of like a hook.
LAZARO, VIKKI Umm, you know, they are similar in a lot of ways.
So what do we think?
Let's just break down what the difference is between a handbag
and a generic pouch.
LAZARO, VIKKI I actually think that this is one
of the things sometimes people overthink, sometimes
when something is so simple you don't trust that it's simple
and you then overthink it.
And from in my opinion, this is one of those instances where people.
LAZARO, VIKKI Think it overthink it.
So a handbag.
It's it's it's kind of like one of things.
You know it when you see it, except unless it's a tough
then you don't you then you gotta measure it.
But you know, like a handbag is something that's here's the difference.
A handbag is something that's clearly meant to be carried on its own.
It's part of the outfit.
It's part of your day.
You're not going to.
LAZARO, VIKKI Normally, take your hand bag and then carry it
in another travel bag.
You know you're not gonna take.
You're not gonna use a handbag to further organize a suitcase
or further organize a tote bag.
It's carried on its own.
It's its own thing.
It has its own destiny.
It's a handbag.
You're using it to carry your personal effects.
LAZARO, VIKKI You're not using it to organize another bag, usually.
LAZARO, VIKKI Umm whereas generic pouches like I said usually are used.
LAZARO, VIKKI As a way to organize your belongings in another,
larger container.
So think about it this way.
You know if you have a generic couch, you're not gonna just walk around
with your generic pouch, you're gonna be using it to store things
and organize your things inside of another, larger BAP.
So that's the main difference between a handbag and a generic pouch.
Handbag is used on its own, it's its own, its own life, its own destiny.
LAZARO, VIKKI A generic tote or generic pouch rather, excuse me,
is going to you is gonna be used to organize another,
larger Bab and hello from Saint Thomas.
LAZARO, VIKKI Umm.
LAZARO, VIKKI So that's the difference, and you usually can see it.
It's usually once you think of it that way, it's usually pretty clear
what the difference is.
LAZARO, VIKKI Just in case it wasn't clear enough,
I'm gonna break it down further.
LAZARO, VIKKI So we have these two.
We have a handbag and we have a generic pouch.
Again, let's say they're the same dimensions, the same material.
LAZARO, VIKKI And you're really not sure it's really, you know, what, Vicky?
These absolutely could be classified in both places.
I don't think that's gonna happen very often.
But let's say for arguments sake that it did.
LAZARO, VIKKI They're absolutely both classifiable as a pouch
which is travel.
LAZARO, VIKKI Or a handbag.
OK, so now we go to the GRID.
LAZARO, VIKKI And the DRI jury 3A heading, which provides,
so you have this, you have this, it can be classified in both places,
it could be classified as a generic pouch under travel
or it could be classified as a handbag.
Absolutely could go either way.
LAZARO, VIKKI The heading which provides the most specific description
shall be preferred to a heading, providing a more general description.
LAZARO, VIKKI Handbags are specifically provided for.
LAZARO, VIKKI It's at the heading level.
This is very specific.
There's either even specifically provided at the subheading level.
LAZARO, VIKKI Where oops.
LAZARO, VIKKI Whereas UM.
LAZARO, VIKKI The generic pouches.
LAZARO, VIKKI Are classified under other their travel sport and similar,
which is other.
It's a basket provision within heading 4202.
So if you have a handbag and it could also be classified as other,
the gris tell us that we're going to classify them
in the more specific provision.
So if it was kind of on the line and it wasn't a clear one or the other,
you would be going, if it can be classified as a handbag,
that's where it goes.
That's because it's the more specific provision.
LAZARO, VIKKI You can't see it, but I talk with my hands a lot,
so I keep touching the mouse by accident, so bear with me on that.
Sorry about that.
LAZARO, VIKKI So that's handbag.
So we pursuant to JRI 3A, if it was class file in both classifiable
in both places it would be a handbag.
LAZARO, VIKKI And then this was a really, really interesting case study,
uh, product that came in.
We got questions on so.
Just wanted to break this down for you because it's really I thought
it was interesting to just show you a little bit of a case study
how we break things down here.
LAZARO, VIKKI So what we have here is there's this round part
at the top is imitation pearls.
They're made of glass.
LAZARO, VIKKI It is permanently attached to these three articles
that are dangling from this round pearled part.
LAZARO, VIKKI And then dangling from the Pearl area, we have a lipstick case.
LAZARO, VIKKI A card case.
Oops.
Show that a little better.
A card case.
LAZARO, VIKKI And a mirror.
So we have three things dangling from this top part.
And our question was, is this considered jewelry or is this Pearl,
this imitation Pearl round part?
Is it just the wrist strap for the other articles that are dangling from it?
LAZARO, VIKKI The really interesting product and we went first
to the explanatory notes.
LAZARO, VIKKI For heading 7117, which is imitation jewellery.
LAZARO, VIKKI And you see here this part.
LAZARO, VIKKI That I've highlighted here.
LAZARO, VIKKI Going to just expand that out for you.
LAZARO, VIKKI It says it is to be noted that articles of personal use
of a kind normally carried in the pocket in the handbag or on the person,
such as those listed in paragraph B of the explanatory notes.
LAZARO, VIKKI Are not regarded as imitation jewelry, so articles
in this paragraph B of the explanatory notes are not recorded,
are not regarded as imitation jewellery.
So next thing we wanna do is find out.
LAZARO, VIKKI What's in this paragraph B?
LAZARO, VIKKI So that's what we did paragraph B.
LAZARO, VIKKI Articles of personal use normally carried in the pocket
of the handbag or on the person such as cigar cigarette cases,
snuffboxes, spectacle cases, powder cases, lipstick holders, Ding, Ding,
Ding, Ding, Ding, Ding, lipstick holders.
LAZARO, VIKKI Are not considered mutation jewelry.
LAZARO, VIKKI And if that wasn't enough.
LAZARO, VIKKI We can also so here we had we did have a lipstick case,
like I said.
Ding, Ding, Ding.
But then we also had it just from the beginning.
Articles of personal use normally carried in the pocket or in the handbag.
Now there's a sub heading in heading 4202 for articles normally carried
in the pocket or the handbag.
And guess what goes there card cases.
So we have this kind of double double exclusion
on this very interesting product.
We have a card case and we have the lipstick case.
So when you have something that is.
LAZARO, VIKKI Anything in that description,
a lipstick case or something
of a kind normally carried in the pocket of the handbag
and say it cannot be imitation jewellery.
LAZARO, VIKKI So this one was classified.
This one will be classified in heading 4202.
LAZARO, VIKKI So I hope I hope you found that one interesting.
LAZARO, VIKKI And that's how we break things down.
We just go through the notes, the precedent and we just, you know,
sometimes it's just through process of elimination to classify things properly.
LAZARO, VIKKI So.
LAZARO, VIKKI We're going to review now and I'm just going
to open the chat box when you know what I can actually see the answers.
So we're gonna review.
I have a couple questions for you.
Just to see if you were paying attention.
So you can answer in the chat box or if well answer in the chat box, go ahead.
So our first question is.
LAZARO, VIKKI How would we classify this molded plastic handbag so you can
either answer by saying, well, you know, let's see what you have, what do you,
how do you think we would classify this multi plastic handbag?
I see one person answered so far.
LAZARO, VIKKI Yeah.
OK.
OK, you got it.
You got it.
So if you said chapter 39.
LAZARO, VIKKI You were correct, and here's the full classification.
And again, plastic articles are CRISPR ton and I asked,
Chris Burton has our plastic expert.
And so this would be 3926 ninety 9985, perfect.
Everybody got it.
So you were paying attention.
Thank you so much.
LAZARO, VIKKI So our next little question is this is multiple choice.
How would you classify this?
Would this be classified as full leather?
LAZARO, VIKKI A wristlet.
LAZARO, VIKKI A handbag.
LAZARO, VIKKI Or a wallet.
LAZARO, VIKKI So faux leather, a wristlet, a handbag or a wallet.
LAZARO, VIKKI OK, I see a lot of people are saying wallet.
Does anybody disagree with wallet?
LAZARO, VIKKI That a lot of fours, a lot of wallets.
LAZARO, VIKKI OK, so if you said wallet, you were correct,
for bonus points.
Can somebody tell me why they decided this was a wallet?
LAZARO, VIKKI Anybody know why they want for the people?
That said, while it did, why did you think it was a wallet?
LAZARO, VIKKI No space for 3D objects, exactly.
It's all about the space, about the space, so yes.
LAZARO, VIKKI So it has no space for three dimensional objects,
so this one would be a wallet regardless of whether or not it had that strap.
LAZARO, VIKKI And then we have which materials are excluded
from the first half of heading 4202?
Here are your choices.
LAZARO, VIKKI Textile PU leather.
LAZARO, VIKKI OK.
Thanks, guys.
So we're gonna move on to the next question now.
LAZARO, VIKKI Can you leather?
LAZARO, VIKKI It's just a little frozen.
Just give it a minute.
It's thinking my computer's a little tired today, I guess.
LAZARO, VIKKI So so far we have the coosawattee thinking.
LAZARO, VIKKI Which materials are not permitted in the first half
of the heading we have plastic sheeting.
LAZARO, VIKKI Molded plastic.
LAZARO, VIKKI Or all of the above.
LAZARO, VIKKI Some of you are getting ahead of me.
OK, so the correct answer is none of the above.
None of these materials are excluded from the first half of the heading.
It's the second half of the heading that has the limits by material.
LAZARO, VIKKI And then our final question is.
LAZARO, VIKKI Sammy, I think some of you already got it.
LAZARO, VIKKI This ones an extra credit is anything ever excluded
from the first half of heading 4202?
LAZARO, VIKKI Wait.
LAZARO, VIKKI Material.
Yes.
Remember, we had that chapter.
Note that excluded plating material from all of heading 4202.
LAZARO, VIKKI Bear with me one second while I just changed my settings
so I can see what you're saying a little better.
Sorry for the delay.
OK, there we go.
Perfect.
OK.
So.
LAZARO, VIKKI The next thing we're going to talk about.
LAZARO, VIKKI If my slides will advance.
LAZARO, VIKKI They won't just bear with me, just seems
to be thinking a little bit too much today.
LAZARO, VIKKI You guys are you guys still seeing the extra credits slide
or are you guys seeing the slides that had advanced?
I for me it's a little frozen.
Can you just give me a little feedback on that?
Are you still seeing the extra credits slide?
LAZARO, VIKKI Can somebody let me know what they're seeing?
LAZARO, VIKKI Does everybody still see the extra credit slide
or are they advancing because on my side they're frozen right now?
LAZARO, VIKKI OK.
LAZARO, VIKKI Umm so I'm getting the red circle.
LAZARO, VIKKI So is there something I should do?
It's just kind of the red circles just going around.
LAZARO, VIKKI Should I stop presenting maybe
and and take control back later?
KIM, JINHEE Sure.
And Vicki?
LAZARO, VIKKI Vicki.
KIM, JINHEE We can reupload it and we upload it for you.
LAZARO, VIKKI Stop.
LAZARO, VIKKI Florida, I will upload you well, if I just stop presenting.
Maybe do you think it will just and then just take it back again.
Do you think that would just reset it?
OK, I'm gonna stop presenting.
KIM, JINHEE Yeah.
LAZARO, VIKKI Guys, I'm so sorry.
Thank you for your patience.
LAZARO, VIKKI Just give me a give us a couple seconds
to just get this resorted.
LAZARO, VIKKI Jin, he maybe you take control because it's saying
if I stop presenting, it's going to unload it.
So do you wanna just take control and then I'll take control back.
KIM, JINHEE Sure.
I actually have voted for you.
Can you take control from me?
Do you see the slides?
LAZARO, VIKKI Is it just my I I still have the old one up
with the stop presenting?
LAZARO, VIKKI So maybe I'll just stop presenting it.
LAZARO, VIKKI It's a guess.
KIM, JINHEE Anything.
LAZARO, VIKKI Yeah, it won't let me.
LAZARO, VIKKI OK.
There we go.
OK, I stopped to presenting.
LAZARO, VIKKI Sorry guys for the technical difficulties,
we should have a backup in just a second.
LAZARO, VIKKI China, did you have?
Did you wanna go on Mike and ask your question while we're waiting for this
to come back up?
LAZARO, VIKKI I see your hand raised.
If somebody had the question that they wanna ask now while we're waiting
for the slides to come back up, I can answer it now hopefully.
KIM, JINHEE Becky, I just.
KONG, FUNG KING Cannot you?
All you have to do is unmute and you can ask the question.
LAZARO, VIKKI That's ohh.
I'm gonna try taking control again.
LAZARO, VIKKI So it's I have my red circle.
I saw something about dimensions.
I'm gonna have to come back to it.
LAZARO, VIKKI So Jenny, can you advance the slides to where I was?
LAZARO, VIKKI If somebody wants to ask me a question on the MIC,
I can take the question while these are uploaded,
but I can't see the chat box right now.
KONG, FUNG KING Amerie, Gina.
I just gave you Mike access.
You're welcome to unmute yourself and ask the question.
LAZARO, VIKKI Janine di are you?
Do you want me to take it back to big?
Take back control and go to where I was or you doing gonna do that?
KIM, JINHEE Yeah, I'm moving right now.
KIM, JINHEE There with me one second.
LAZARO, VIKKI Thank you.
KIM, JINHEE Becky, do you see the slide where you left?
Can you take, take take take control?
LAZARO, VIKKI I I see only I see only the first slide.
LAZARO, VIKKI Oh, I see it now, but I have this still the circle.
LAZARO, VIKKI Slide 132, there's everybody saying.
Thank you, guys.
OK, let's see.
OK.
Sorry for that little detour, guys.
This is the the world of the computer has its own.
LAZARO, VIKKI So on mine, so I'm trying to take control now, jinhui.
LAZARO, VIKKI Join here.
It's not letting me take control, so can you just advance them for me?
LAZARO, VIKKI Oh, you know what?
Never mind.
It's it's just slow.
KIM, JINHEE No.
LAZARO, VIKKI OK.
LAZARO, VIKKI OK guys, so if you could just let me know
if you're now seeing a slide that says binding rulings heading heading 4202.
LAZARO, VIKKI Umm.
So I'm gonna go over what we're looking for and binding rulings
in this more virtual environment and then I will take all your questions.
We're gonna take down the slides and I will answer all your questions
as best I can.
So let's just get through this.
Hopefully the computer will be cooperative.
And so just bear with us.
So what we're looking for with binding rulings and heading 42,
we're shifting away from physical samples.
LAZARO, VIKKI Because again, we do wanna, you know,
the 12 inch rule is only a guideline, but we still need to have an idea
of those outer dimensions.
And if there's anything particularly unique or unusual about the bag,
take a photo of that too.
You know, if it's compartmentalized on the inside.
LAZARO, VIKKI Perfect.
That's a good question.
So if a phone case has space for additional items like some card slots
for example, those would be in 4202.
If they only have the space for the phone.
So it's only containing one item, just the phone and no pockets or slots
or anything of that nature for other articles, it would be 39,
assuming it's plastic.
Of course, if it does have any sort of wallet like features,
those would remain in 4202.
HEMMEN, COLLEEN OK.
Thank you.
LAZARO, VIKKI That answer your question.
HEMMEN, COLLEEN Yeah, because we just had something come back from court
and they just dismissed it.
LAZARO, VIKKI Ohh.
LAZARO, VIKKI Ohh well, we already that that already.
That issue did already go to court and was decided on.
So that's probably I would guess that's why.
HEMMEN, COLLEEN OK.
LAZARO, VIKKI OK, you could look at the OtterBox case if you want.
HEMMEN, COLLEEN Thank you.
HEMMEN, COLLEEN Yeah.
LAZARO, VIKKI The court case you might want to read that.
HEMMEN, COLLEEN Right.
LAZARO, VIKKI OK, so ping Lin.
I saw your name and if you and guys if you
if you could just stick your hand down.
When when you're done with your question that would be helpful.
So what was your question?
Ping Lin My question is, we have a tote bag
that made up one side is paper and the rest of it the tote are made of textile.
LAZARO, VIKKI OK.
Ping Lin And what would be fit goes into as an article paper
or the articles of a 42 or two.
LAZARO, VIKKI What would you say?
It's one side paper?
What do you mean?
Is it just made of paper or is it paper that's covering something?
Ping Lin Paperboard.
Ping Lin Yeah, it's it's just outside of paper for you to draw on.
LAZARO, VIKKI For you to draw on.
Ping Lin You can design your own front page, I mean.
LAZARO, VIKKI But I mean is it like, but I'd say what I'm pitch.
Is it like a paper bag that like the store gives you
with your your purchases or is this a reusable bag?
Ping Lin It's a reusable bag.
LAZARO, VIKKI So I'm going to assume that the paper is over another material,
is that correct?
Ping Lin No.
LAZARO, VIKKI So what's keeping the bag from falling apart?
If it's just paper, not I'm not really.
Ping Lin The rest of it, yeah.
The rest of it is text.
Now it's just like thick paper, like paper board.
Yeah.
LAZARO, VIKKI Thick paper.
LAZARO, VIKKI Oh paperboard.
Ping Lin Yeah, like cardboard, kind of.
LAZARO, VIKKI I mean, cardboard and paperboard are permitted
in the second half of the heading, so it's if you have two materials
but you have a composite good, we'd have
to make an essential character determination.
So it really depends on which material would be the essential character.
I'd have to take a look at it.
LAZARO, VIKKI Umm, so you'd want to look at the value.
The is one of which one of the materials is using the the majority
of the outer surface.
Ping Lin OK.
LAZARO, VIKKI And you know which maybe which material is creating like
which which material is creating the most visual effect.
Those are usually three items that we'll be looking into
for making an essential character determination.
So there's not one answer there.
It would depend on the other features.
Ping Lin OK, alright.
LAZARO, VIKKI Sounds like an unusual product.
Ping Lin Yeah.
Thanks.
LAZARO, VIKKI OK, so I'm reading.
I'm gonna read them.
I'm gonna.
I'm gonna go to the hands.
But I do see a message here.
Some importers may not be willing to allow publication
if photos are published.
Very true.
We would need to get the importers.
LAZARO, VIKKI Uh, permission for sure.
On something like on a change like that.
So I see couple more hands.
Let me just see if I could figure out.
LAZARO, VIKKI How to do this myself?
Here you see, I think if I go here to the people.
LAZARO, VIKKI So ping lend you have another question or is your hand
just still up from before?
LAZARO, VIKKI OK.
So Jenny, can you just read out another name?
Because I can't get to the chat box properly.
KIM, JINHEE There are Gina.
LAZARO, VIKKI Gina, can you ask your question?
LAZARO, VIKKI OK, so maybe go to the next person.
KIM, JINHEE Martha.
LAZARO, VIKKI Call Gene Martha.
KIM, JINHEE This long.
Martha Long Already asked my question.
Thank you.
LAZARO, VIKKI OK.
LAZARO, VIKKI So you could take your hand down.
Anybody else have a question that they wanna that that we wanna
if you wanna just jump in.
If you have a question.
Nadzeya Mizavets Yes, hi, Vicki.
My question is, are dehydration bag limited
to the over the shoulder style like backpack or can it be
for example a waist pack?
LAZARO, VIKKI You know, that's a complicated question.
There's not one answer if it's if the hydration component
is filling up the backpack.
I'm sorry, filling.
So obviously, they're usually backpacks or over the shoulder.
LAZARO, VIKKI Umm.
Is the bladder that you're talking about?
Is it completely dedicated to that particular ***** Pack?
Is it attached?
Is it detachable?
What are some?
Nadzeya Mizavets Well, it is detachable.
It is fully in the biggest pocket of the, you know,
the ***** pack style kind of.
And it has the tube that goes to over like over the shoulder to the mouth.
LAZARO, VIKKI So it's it's dedicated to the.
It's like they're fitted one to the other.
Nadzeya Mizavets Yes.
LAZARO, VIKKI Yeah.
Umm.
LAZARO, VIKKI I mean I'm.
I'm, you know, just as an advisory since I'm not seeing it.
I would say if it's, if they're dead, if the if the bladder is dedicated
to the ***** pack and there isn't really a lot of space for other articles,
it probably would be fine.
LAZARO, VIKKI But if you're just taking, like some sort
of like random bottle and just putting it in the ***** pack,
then that it could be used for anything, you know, cause you're looking
at it would be have to be a composite code where it's adapted to each other.
Nadzeya Mizavets Uh-huh.
LAZARO, VIKKI You know, and then the primary part is the bladder,
if it has lots of space for other things, then probably not.
Nadzeya Mizavets Thank you.
LAZARO, VIKKI You're welcome.
LAZARO, VIKKI Umm.
So if if you if you already asked your question,
if you wouldn't mind taking your hand down
and then whoever has a question left, you could just jump in at this point.
KIM, JINHEE Miss Leslie.
Looney, Leslie Yes.
How would you classify detachable pouch?
It attaches with a steeper.
LAZARO, VIKKI Ohh miss, I'm sorry I can't understand what you're saying.
Can you speak up a little more?
Looney, Leslie Yes, sorry.
Looney, Leslie Uh, can you hear me now?
LAZARO, VIKKI Sort of.
Looney, Leslie OK, sorry.
Looney, Leslie How would you classify a pouch or bag that attaches
to the Super to a pen?
LAZARO, VIKKI I'm sorry, I didn't understand what you said.
I heard.
I heard pouch and then I didn't hear the rest.
Looney, Leslie OK, it it is a pouch that attaches to a pen with a sleeper.
LAZARO, VIKKI So it's attaching to the pans like it's a pocket of the pans.
Looney, Leslie Yes.
Looney, Leslie Yes, and it detaches.
LAZARO, VIKKI It detaches.
Is it being imported with the pans or is it being imported on its own?
Looney, Leslie With the pants.
LAZARO, VIKKI So if it's, if it's, if it's, so that to me,
I don't handle the pants.
So you'd wanna send this product to the NIS for the pants
and you know it's men's or woven or women's and all that stuff.
But to me, it sounds like it's just a detachable pocket to the pants.
Is that correct?
LAZARO, VIKKI So it's to me it sounds like a composite good
and even if it was a detachable pocket that came in on its own,
that probably still wouldn't be 4202 cause it's just more like a,
quote UN quote, part of the pans.
It's not really something that you would buy on its own at retail
or something that you would even be able to use on its own.
If it's just a detachable pocket.
Looney, Leslie Yes, correct.
LAZARO, VIKKI Does that make sense?
Looney, Leslie Yes.
Umm, thank you.
LAZARO, VIKKI OK.
You're welcome.
LAZARO, VIKKI Next question, if you could just if you,
if I haven't answered your question yet, just feel free to just jump in.
LAZARO, VIKKI I'm gonna try to see if I can open the chat box.
It's so my computer is still frozen.
Guys, I'm so sorry.
KIM, JINHEE This.
LAZARO, VIKKI It works for it.
It works fine for you know, 364 days out of the year.
And then you have to give a presentation.
It freezes up.
Luke Swenson 5.
LAZARO, VIKKI OK, so I heard a voice.
Luke Swenson Hi.
Excuse me.
I just had a question regarding the three dimensional objects.
LAZARO, VIKKI Sure.
Luke Swenson Umm so the issue is that all objects have 3 dimensions
including paper dollar bills.
So is there a limitation on the size of the object that goes inside
of the container to determine whether a container is a wallet or a handbag?
LAZARO, VIKKI Flat goods for for the purposes of this conversation,
I would consider paper to be flat a flat good.
When I say 3 dimensional objects I mean lipstick.
LAZARO, VIKKI Point purses, things of that nature, not the objects
that are normally associated with the wallet.
So.
LAZARO, VIKKI Umm, we'll say paper paper currency would be associated
with the wallet credit cards.
LAZARO, VIKKI Umm, obviously coins would be associated with the wallet.
A checkbook.
LAZARO, VIKKI Those kind of objects that normally are carried
in a wallet would be what we're calling quote,
quote UN quote flat goods flat items.
LAZARO, VIKKI And then UM.
LAZARO, VIKKI The three dimensional objects would be lip gloss,
things that you saw in the in the webinar like lip gloss, a brush,
makeup brush, cosmetics, things of that nature.
LAZARO, VIKKI Does that make sense?
Luke Swenson Yes, thank you.
LAZARO, VIKKI You're welcome.
LAZARO, VIKKI I did see a couple of questions in the chat box
that I didn't get to.
LAZARO, VIKKI Umm.
So let me just see if I is.
If anybody else has a question that I still missed,
you could either go on MIC.
LAZARO, VIKKI Or, uh, maybe Jen here.
You could read them to me.
KIM, JINHEE Yes, from Mr Chris Barrett for storage boxes
with fabric exterior classify in Chapter 63 does adding straps
to the box a place these in 42 or two.
LAZARO, VIKKI No, not necessarily.
No.
If you have a box, a store, a home storage box.
LAZARO, VIKKI We're looking at the use the primary use,
so if the primary use is domestic storage.
LAZARO, VIKKI Office storage, home storage, shed storage,
anything of that nature.
LAZARO, VIKKI It would not be in heading 4202 and it's absolutely normal
and acceptable for a box to have some convenience handles
to maybe move it to another room or something like that.
So we're really looking at the the intended use
if the intended use is domestic storage rather than transporting the contents,
then it would still be excluded from 4202.
Again, I can't say for sure it would be 63 or 7
because that's another NIS is heading and I don't know those rules,
but I can say the fact that you added.
LAZARO, VIKKI Handles to something.
LAZARO, VIKKI Doesn't change the classification, just like we said
with the the wristlets, the handbags, wallets that strap versus strap,
we're looking at the use not not whether or not maybe has a handle.
LAZARO, VIKKI So I hope that was helpful.
LAZARO, VIKKI Umm any other questions that I need to answer?
LAZARO, VIKKI We see maybe one more hand.
I'm not sure if it was somebody that.
LAZARO, VIKKI Already was answered.
LAZARO, VIKKI Any more questions you can raise your hand or ginnies,
uh, monitoring the chat box.
KIM, JINHEE Miss Heather.
KIM, JINHEE Miss Heather, you cannot question your mic is on.
Simpson Kong, Heather L. Yep.
Simpson Kong, Heather L. Thank you.
Hi, Vicky.
We really love your webinars and we sing your space song all the time.
LAZARO, VIKKI Ohh, good, good, good.
Simpson Kong, Heather L. We have a we we are back and forth on.
Simpson Kong, Heather L. Earbud holders of molded silicone.
LAZARO, VIKKI Ohk OK.
Simpson Kong, Heather L. By application
I mean we are after the semi colon and molded silicone isn't a named.
Simpson Kong, Heather L. Uh.
Material.
So we're looking, we're like 30, it's at 39 or we are at 4202 ninety nine.
LAZARO, VIKKI OK.
Well, let's back up a second.
So silicone is molded plastic.
LAZARO, VIKKI If it is truly silicone and there's nothing covering it.
LAZARO, VIKKI Umm.
LAZARO, VIKKI OK, but so here's my question for you.
Is it fitted for the eye buds or is it just like a generic pouch
of molded plastic that just happens to be small?
Simpson Kong, Heather L. We would have
to look inside an answer that question.
LAZARO, VIKKI Yeah.
So that's what you're looking for, because in addition to the named items
in the first half of the heading, don't forget fitted containers
are also you know there's the and this webinar wasn't specifically
on on this issue.
We can't cover everything in every hour but fitted containers.
LAZARO, VIKKI Are if it's fitted for something specific, it could also be
in the first half of the heading, so if it's fitted for the year buds,
I would say 4202.
If it's silicone with something over it,
you might wanna take another closer look, but if it's just
sort of a generic silicone.
Simpson Kong, Heather L. OK.
LAZARO, VIKKI Pouch I guess like I don't like pouch doesn't feel like
the right word.
But you know what I mean.
It's just a generic silicone molded plastic container and it's not fitted.
Then it probably is excluded.
Simpson Kong, Heather L. OK.
Thank you.
LAZARO, VIKKI You're welcome.
LAZARO, VIKKI OK guys, I see something in the chat box.
Is that a new question or is that the one I just answered?
LAZARO, VIKKI Nothing.
LAZARO, VIKKI Going once on questions.
LAZARO, VIKKI Going twice.
LAZARO, VIKKI Umm jinhee, should we?
We should we.
Should we be bold and try to pull up this the slide
with our information on it.
LAZARO, VIKKI Or you know what's in here,
if you could just put my email address in your in your email address
in the chat box, that might be better.
So I'm gonna just put my email address where you can reach me
in the chat box, and then my associate, Jenny Kim is excellent.
If you have any questions on.
LAZARO, VIKKI Really, anything related to is did we receive your sample
or any of that kind of organizational stuff?
She's amazing for that.
So she's gonna put that her email address and my email.
And that's basically what my last slides
where we're just our contact information.
So we're gonna put that in the chat box instead of fighting
with the slides again.
LAZARO, VIKKI And then, unless there's any more questions,
that's it for me guys, I hope that was helpful.
Sorry for the technical issues.
I'm so sorry.
You know, whatever can go wrong will go wrong.
It's just kind of the law of the universe.
I don't know why.
LAZARO, VIKKI But that's it.
So.
LAZARO, VIKKI Let us know if you need anything.
We're happy to, you know, answer your rulings as well.
LAZARO, VIKKI And if not, we'll see you next year in the next webinar.
LAZARO, VIKKI Thank you so much guys.
You're so welcome, Cheryl.
LAZARO, VIKKI Cheryl, sorry if I pronounce your name wrong.