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HQ 088194

January 2, 1991

CLA-2 CO:R:C:G 088194 DFC



Mr. Carl Davis,
Director, Trade Operations
One Bowerman Drive
Beaverton, OR 97005-6453

RE: Standards for measuring plastic coating on leather.

Dear Mr. Davis:

In a letter dated November 2, 1990, you inquired as to what formal testing procedure and standards are applied by the U.S. Customs Service in measuring the thickness of plastic coating on footwear leather.

You have posed 5 specific questions. We will reply to questions 1 and 5 separately. Since the answers to questions 2 through 4 are dependent on each other, we will respond to them jointly.

Question No 1: Is the Satre method to be used?

The method used by U.S. Customs laboratories is described below. We are not aware of a method known specifically as the "Satre" method. We are aware of a British method for measuring thickness of surface coatings on leather. An organization known as the Satra Footwear Technology Centre participated in the development of the procedure. The U.S. Customs method and the British method are similar.

Question No. 2: How many tests should be performed on a standard shoe?

Question No. 3: Where, on a shoe, should the samples be taken?

Question No. 4: If the samples vary in thickness, will Customs take an average of the tests or apply some other standard?

Three to five individual measurements are taken on every portion of the shoe that is different. For example, if a shoe is constructed of only one piece of leather, then five measurements are taken. If a shoe is constructed of several pieces of leather that are attached, then 3 to 5 measurements on each of the several pieces are taken and averaged. A "different piece" can simply be a different color placed on the same piece of leather. Measurements are taken at representative sites on each different piece of leather. Care is taken to avoid areas that are deformed either due to construction of the article or due to imperfections in the leather. The measurements are averaged to arrive at a final result.

Question No. 5: If the coating is laminated on the leather, will the adhesive be included or excluded from the measurement?

Under our procedures, the adhesive is not being included in the measurement of the thickness of a laminated coating.


John Durant, Director

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