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RULING N340682 · NY Ruling · 2024-06-14
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Tech sleeve HTS 4202.92.9700: why the plastic outer surface set the duty

HTS 4202.92.97.00 Base duty 17.6% Origin India
What this is Public CBP CROSS case study · trade-compliance education · tariff-risk awareness · AI-assisted reference Not a formal HTS classification, customs-broker advice, or legal opinion for your shipment.
A · Facts Source: CBP CROSS public record
Importer's question
Under what HTS heading does a padded laptop/tablet sleeve with a PU-plastic outer surface over a sheepskin base fall?
Product description
A large envelope-style padded sleeve built to store, protect and carry a laptop or tablet. It has a front flap with a button-loop closure, padded interior and a textile lining. Roughly 10.5 in wide by 15 in high by 1 in deep. The base is sheepskin, but the outer surface is coated with polyurethane (PU) plastic sheeting that is visible, tactile, and completely covers the leather beneath, so the plastic gives the piece its color and texture.
CBP holding
CBP classified the tech sleeve under HTS 4202.92.9700 at 17.6% ad valorem.
CBP reasoning
The article is the kind of case or container heading 4202 covers. Because the outer surface constituent material is the plastic sheeting rather than the leather base, CBP placed it in the 4202.92 branch for containers with an outer surface of plastic sheeting or textile, then in the 'other, other' residual line 4202.92.9700.
Basis
GRI 1GRI 6
Verify against the original: /docs/ny/2024/n340682.doc ↗ · this layer paraphrases the public record; the CROSS original controls.
B · Case analysis ETDETA original analysis · educational

CBP classified this padded laptop/tablet sleeve under HTS 4202.92.9700 at 17.6%, because the outer surface is PU plastic sheeting, not the sheepskin underneath — and the outer surface material is what drives the 4202 subheading and the rate.

02Why this heading, and not the obvious one

Heading 4202 covers cases and containers of the trunk/bag/similar-container family, and a laptop or tablet sleeve fits squarely there. The fight inside 4202 is over the outer surface constituent material, since that splits the subheadings and the rates. Here the base is sheepskin, so you might expect the leather branch (4202.31 / 4202.91). CBP didn't go there. The PU plastic sheeting is visible, tactile, and completely obscures the leather, giving the article its color and texture — so the plastic, not the leather, is the outer surface. That pushes it into 4202.92 (outer surface of plastic sheeting or textile), then down the residual line to 4202.92.9700 at 17.6%. This tracks the long-standing rule that for 4202 goods you classify by what your hand actually touches on the outside, not by what sits underneath. Final classification depends on the importer's actual product and should be confirmed by a licensed customs broker.

03What it means for importers
  • Confirm from your BOM and a lab or supplier statement which material forms the true outer surface — plastic coating vs. exposed leather changes the subheading.
  • Budget landed cost at 17.6% for plastic-surface sleeves; don't assume the leather rate just because the base is sheepskin.
  • Keep the sample, spec sheet and closure/lining details on file so an entry matches the facts CBP relied on here.
04Duty impact of the two paths
PathCodeBase duty
Path CBP used — plastic outer surface4202.92.970017.6%
Alternative — leather outer surface illustrative4202.91.90004.5%
On a $40,000 shipment of sleeves, 17.6% is $7,040 in base duty. If the outer surface had been leather and fell to a 4.5% line, that would be about $1,800 — a roughly $5,200 swing on the same value. That is base-rate math only. India-origin goods are not subject to Section 301, but always verify the current Chapter 99 status, any add-on measures and exclusions for your specific product at time of entry before you rely on a single number.

Illustrative comparison only. The alternative heading is one contrast possibility — the exact subheading for a different product configuration would need separate analysis (other Chapter 84/85 or specific provisions may apply). Any Section 301 / Chapter 99 figure assumes the goods remain subject to that measure at the time of entry; always verify the current Chapter 99 status and any applicable exclusions.

05Compliance risk flags
  • Calling the sleeve 'leather' on the invoice while the outer surface is PU plastic creates a mismatch between paperwork and the good's actual surface material.
  • CBP can verify these material facts on exam; a coating that doesn't fully cover the leather could change which branch applies.
  • Residual 'other, other' lines like 4202.92.9700 leave less room to argue a lower rate, so the outer-surface finding does the heavy lifting.
07If the product changes (edge cases)
  • The PU coating is thin or partial, leaving the sheepskin visible and tactile as the outer surface. → The outer-surface material could read as leather, pointing toward a 4202.91 leather branch at a much lower base rate.
  • The outer surface is woven textile instead of plastic sheeting. → Still 4202.92, but the man-made vs. other textile distinction can move the exact 8/10-digit line and the rate.
  • The item is redesigned as a fitted molded case for a specific device rather than an open envelope sleeve. → It stays in 4202 but the specific-fit and material analysis should be re-run, as the subheading can shift.
08Practitioner's takeaway

For anything in the 4202 bag-and-case family, the number that moves your duty is the outer surface material, not the core. I've seen importers assume 'sheepskin base' means a leather rate and get surprised at 17.6% because the plastic coating is what CBP touches. Document the surface before you book.

09Importer checklist — what to prepare for similar products
  • Invoice wording that names the actual outer surface material (PU plastic sheeting), not just the base.
  • A BOM or supplier statement showing coating vs. base and whether the plastic fully covers the leather.
  • The physical sample or clear photos of the flap, closure and lining.
  • Dimensions and intended use (laptop/tablet storage and carry).
  • Country of origin documentation — here, India.
  • A licensed broker's review of the outer-surface finding before you lock in the entry rate.
FAQFrequently asked questions

Why is this tech sleeve HTS 4202.92.9700 and not the leather rate?

In ruling N340682 CBP found the PU plastic sheeting, not the sheepskin base, was the outer surface — visible, tactile and fully covering the leather — so it fell in the plastic-surface branch at 17.6% rather than a leather line. Your own product's surface should be confirmed with a broker.

What duty rate applies to a laptop sleeve under 4202.92.9700?

The ruling states a general rate of 17.6% ad valorem. Rates change, so verify the current HTS and any Chapter 99 measures for your specific goods and origin at time of entry.

Does Section 301 apply to this India-origin tech sleeve?

Section 301 targets China-origin goods, and this ruling covers goods from India, so it wouldn't apply here. Always confirm the current Chapter 99 status and origin for your actual shipment before relying on a rate.

Would a leather-surfaced sleeve get a lower duty than 4202.92.9700?

A sleeve whose actual outer surface is leather can point toward a 4202.91 branch with a much lower base rate. The dividing line is which material your hand touches on the outside; a broker should confirm the finding for your product.

What documentation supports a 4202.92.9700 classification for a padded sleeve?

Keep a sample, a BOM or supplier statement identifying the outer surface material and coating coverage, dimensions, intended use and origin. These match the facts CBP relied on and help an entry hold up on exam.

This section is an educational reading of a public ruling, written to help importers understand classification reasoning and tariff risk. It does not make a classification decision about your specific goods.
BW
Founder & CEO, ETDETA · 30+ years in trans-Pacific ocean shipping; earlier at APL, COSCO, SEALAND and P&O; founded ETDETA in 2005.
Research & editorial: ETDETA Trade Research Group · reviewed before publication. General educational information, not a determination.
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This is general educational information compiled from public CBP CROSS rulings to help importers understand classification reasoning, duty differences and compliance risks. It is not a formal HTS classification, customs-broker service, entry instruction, duty determination, or legal advice for any specific shipment. Final classification depends on a product's actual material, construction, use, accessories, invoice description, country of origin, and current legal status. Importers should confirm with a licensed customs broker or trade counsel, or request a binding ruling from CBP, before entry.