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NY 808652

April 10, 1995

CLA-2-64:S:N:N8:346 808652


TARIFF NO.: 6406.10.6000

Mr. David C. Lee
Armen Cargo Services
9111 South La Cienega Blvd., Suite 160
Inglewood, CA 90301

RE: The tariff classification of two boot shafts from China or Taiwan.

Dear Mr. Lee:

In your letter dated March 24, 1995, for Cali Plastic Shoes and Santa Fe Footwear Company dba Allied Polymer, you requested a tariff classification ruling.

Your letter states "four shoe parts" are being submitted and "Samples along with descriptive drawings of completed items are enclosed..." We received two samples, but no drawings.

The first sample, identified as 780C, is a 5 inch high boot shaft, with an all plastic external surface that has sewn-on plastic accessory trim pieces, 4 metal D-rings and a partial textile fleece lining. The fleece lining ends about 2 inches short of the bottom opening of this boot shaft.

The second sample, identified as 291C, is a boot shaft about 7.5 inches in height, with a plastic external surface, a partial textile fleece lining which ends about halfway down the inside of the shaft, and with a tubular braided textile shoe lace which is threaded through several metal eyelets while passing around and inside the sleeve of a cinchable top opening. This "cinch lace", while removable, is not intended to be removed, since reinsertion into the topline is difficult.

We consider the "cinch lace" inserted in the plastic boot shaft to constitute a "composite good" and as such, to be classifiable together with that boot shaft upper part.

The applicable subheading for the two boot shafts, identified as 780C and 291C, will be 6406.10.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for footwear uppers and parts thereof, which are less than "formed uppers" and whose external surface is predominately rubber and/or plastics. The rate of duty will be free.

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

A copy of 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 brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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