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NY 867962

November 14, 1991

CLA-2-64:S:N:N3D: 346-SM 867962


TARIFF NO.: 6406.20.0000; 6406.99.9000

Mr. D.G. McKenny
John V. Carr & Son, Inc.
POB 307
Derby Line, VT 05830

RE: The tariff classification of heel lifts from Canada.

Dear Mr. McKenny:

In your letter dated 10/9/91, received here on 10/18/91, you requested a tariff classification ruling for PPD Thermoplastic.

Based on the information you now supply and the samples which you previously submitted, we note that the imports in question are of two basic types, i.e., "heel pin lifts" and "heel dowel lifts". Both types have a plastic heel of various sizes and a steel "nail" that will be driven into the high heel of a shoe. The pin lifts have "nails" which are .65 inches in length and weigh one gram. You state the only purpose of these "nails" is to attach the rubber lift to the heel. The dowel lifts have "nails" which are between 1 to 2.75 inches in length and weigh between 1.8 to 5.4 grams. You state that these "nails" which are dowels "also reinforce the shoe heel". The weight of the plastic lifts by themselves vary from .3 to 3.2 grams depending on their size and thickness.

The applicable subheading for the "heel pin lifts" will be 6406.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for outer soles and heels which are essentially of rubber or plastics. The rate of duty for products of Canada is 3.7 percent through 1991.

For the "heel dowel lifts", it will be 6406.99.9000, HTS, which provides for parts of footwear, which are other than uppers or parts thereof; whose essential character is not given by wood, rubber and/or plastics, textile materials or leather; and which are not nails, boot protectors, zippers, ornaments or trimmings, or, in general, most parts which could be used in articles besides footwear. The rate of duty for products of Canada is 10.7 percent through 1991.

We note that PPD has waived their right to summons denied protest 0712-91-000374 and that you stated that there are no other pending Customs transactions regarding this item.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy if this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be bought to the attention of the Customs officer handling the transaction.


Jean F. Maguire

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