Soft-sided insulated cooler backpack, leakproof PEVA lining, holds 30 cans, with bottle opener

GRI Reasoning

Step 1 — GRI 1: Heading identification

Heading 4202, HTSUS expressly covers "insulated food or beverage bags, knapsacks and backpacks" of textile materials. The subject article is a soft-sided insulated cooler backpack with an outer surface of polyester (a man-made textile fiber), a PEVA lining, and foam insulation. It fits squarely within the eo nomine language of heading 4202.

Heading 3924 covers "tableware, kitchenware, other household articles…of plastics." Rulings HQ 960997 and HQ 961515 applied 3924.10.50 to cooler bags whose outer surface was PVC plastics. Because the outer surface of this article is textile (polyester), not plastics, the SGI/3924 line of rulings does not control; the 4202 classification is appropriate per CBP rulings N291344 and N321341, both of which involve polyester-outer / PEVA-lined insulated cooler backpacks classified under 4202.92.0807.

Step 2 — GRI 6: Subheading selection within the verified HTS rows

The supplied HTS rows include 4202.12 ("trunks, suitcases, vanity cases, attache cases, briefcases, school satchels and similar containers… with outer surface of textile materials") and within it, 4202.12.81 for "of man-made fibers" at a general rate of 17.6%, with statistical breakouts 4202.12.81.30 (attache/briefcase-type) and 4202.12.81.70 (Other). Neither 4202.92 nor 4202.92.0807 appear in the supplied HTS rows. The deepest verified code consistent with a man-made fiber textile outer surface in heading 4202 is 4202.12.81.70.

Note: The two controlling rulings (N291344, N321341) use subheading 4202.92.0807, which is in the 4202.92 branch ("traveling bags, insulated food or beverage bags, toiletry bags, knapsacks and backpacks… with outer surface of textile materials"). That branch is more precisely correct for a backpack/insulated beverage bag, but it is absent from the supplied verified HTS rows. A licensed customs broker must confirm the correct subheading.

Step 3 — Duty rate (from verified HTS rows)

• 4202.12.81 general rate: 17.6% (as stated in verified HTS row)
• Section 301 China overlay: 4202.12.81 carries footnote referencing 9903.88.03, which per the supplied Chapter 99 rows imposes "the duty provided in the applicable subheading + 25%" on articles the product of China (subject to exceptions listed in that heading). This is an additional-overlay flag to verify — do not apply without confirming current applicability and any exclusions.
• Combined exposure to verify: 17.6% + 25% Section 301 = ~42.6% (pending broker verification of 9903.88.03 applicability and any active exclusions).

Step 4 — Bottle opener accessory

Under GRI 3(b), the bottle opener is ancillary to the bag's primary function and does not displace classification. Per ruling HQ 953275, accessories that do not alter the primary purpose do not change the heading.

Step 5 — Annual duty estimate (illustrative, pending verification)

5,000 units × $10.70 = $53,500 declared value. At 17.6% general + 25% Section 301 ≈ 42.6%: ~$22,791 annually (to be confirmed after broker verifies correct subheading and current 9903.88.03 status).