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HQ 084712

August 24, 1989

CLA-2 CO:R:C:G 084712 HP


TARIFF NO.: 6403.19.6060

Ms. Mary Murphy
Customs Coordinator
Reebok International Ltd.
150 Royall Street
Canton, MA 02021

RE: Classification of shoelaces imported with shoes

Dear Ms. Murphy:

This is in reply to your letter of May 11, 1989, concerning the tariff classification of shoelaces imported with shoes, produced in Korea, Taiwan, Indonesia and the Philippines, under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).


The merchandise at issue consists of three pairs of shoe lacings, imported in the same packing container with one pair of shoes. The lacings are of a matching style and color with the shoes. The instant sample is a ladies "free style," leather upper, athletic shoe, fully covering the ankle, in black with blue trims, designed for aerobics. You state an intention to incorporate this multiple lace feature into other shoes.


Does the multiple lace-shoes combination form a set under GRI 3 for classification under the HTSUSA?


Heading 6403, HTSUSA, provides for footwear with uppers of leather. Heading 6307, HTSUSA, provides for, inter alia, the textile laces. The General Rules of Interpretation (GRI's) to the HTSUSA govern the classification of goods in the tariff schedule. Goods which cannot be classified in accordance with GRI 1 are to be classified in accordance with subsequent GRI's, taken in order.

GRI 3 states, in pertinent part:

When by application of Rule 2(b) [goods of more than one material or substance] or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows:

(b) Mixtures, composite goods consist- ing of different materials or made up of different components, and goods put up in sets for retail
sale, which cannot be classified by reference to 3(a) [which requires that goods be classified, if possi- ble, under the more specific of the competing provisions], shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable.

The Explanatory Notes to the HTSUSA constitute the official interpretation of the tariff at the international level. Explan- atory Note (X) to GRI 3(b) provides:

For the purposes of this Rule, the term
"goods put up in sets for retail sale" shall be taken to mean goods which:

(a) consist of at least two different articles which are, prima facie, classifiable in different headings.

(b) consist of products or articles put together to meet a particular need or carry out a specific activity; and

(c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).

For the sets mentioned above, classification is made according to the com- ponent, or components taken together, which can be regarded as conferring on the set as a whole its essential character.

It is clear that the shoes/laces combination forms a set, as defined above, with the shoes imparting the essential character. The number of laces included is not relevant, as long as each set is put together to meet a particular need. It is also not relevant whether the set is imported laced together, or merely boxed. The latter, as shown by Note (X)(c), supra, fulfills the requirements for a set under the HTSUSA.


As a result of the foregoing, the instant merchandise is classifiable under subheading 6403.19.6060, HTSUSA, as footwear with outer soles of rubber, plastics, leather or composition leather and uppers of leather, sports footwear, other, for other persons, for women and misses, other. The applicable rate of duty is 10 percent per pair. The laces require a visa in textile category 369 if composed of cotton, a visa in textile category 669 if composed of other materials.


John Durant, Director
Commercial Rulings Division

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