CBSA Issues 'Interpretative Policy' on Travel Goods Classifications

The shift in travelers' habits "has given rise to an ongoing evolution in the design and construction of travel goods," creating the need for further customs classification guidance, the Canada Border Services Agency said in Memorandum D10-15-29. The new memo, which was issued June 20, outlines the CBSA's "interpretative policy with respect to the tariff classification of suitcases, travelling bags, backpacks (rucksacks) and handbags of heading 42.02," it said. Chapter 42 covers "Articles of leather; saddlery and harness; travel goods, handbags and similar containers; articles of animal gut (other than silk-worm gut)" and heading 42.02 includes trunks, suitcases and briefcases.

The recent shift in travel bags "has resulted in travel goods with versatile functionality and constructed from materials that are both lightweight and durable," the agency said. "The purpose is to provide travellers with luggage options that suit their unique travel needs and preferences, at the same time addressing transport carrier size and weight restrictions." Notably, "there is no size or dimension criteria used to determine whether a piece of luggage is classified as a 'suitcase' or as a 'travelling bag,'" the CBSA said.

The CBSA goes on to spell out guidelines for classifying suitcases, traveling bags, backpacks and handbags. Suitcases are classifiable in subheadings, 4202.11, 4202.12, 4202.19. Traveling bags are classifiable in subheadings 4202.91, 4202.92, 4202.99. Backpacks "are all classified under subheading 4202.9X as 'Other' travel goods," including subheadings 4202.91.20 00, 4202.92.20 21, 4202.92.20 29 and 4202.99.90.00, CBSA said. Handbags are classifiable in subheadings 4202.21.00.00 and 4202.22, it said.

The CBSA memo also explains that Chapter 42 specifically differentiates between handbags and travel goods. Handbags are meant to carry objects for routine daily life, but "daily essentials can vary significantly from one person to another, which means that handbag sizes can also vary significantly," the agency said. "Consequently, in situations where it is difficult to differentiate between whether a bag is classified as a 'handbag' or as a 'travelling bag', for tariff classification purposes, a handbag must not exceed a linear measurement of 90 cm. Linear measurement is the sum total of the bag’s length, height and width. Any linear measurement in excess of 90 cm is to be classified as a travelling bag or other bag of subheading 4202.9X. Totes, for example, are a general term used for either a handbag of 4202.2X or an 'Other' bag of 4202.9X with the classification depending on the size criteria."