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NY N010919

May 25, 2007



TARIFF NO.: 6406.99.3060

Mr. Stephen Martorino
Spectrum Customs Border Services
4050a Sladeview Cr.
Mississauga, Ontario
Canada, M2H 2Y3

RE: The tariff classification of removable insoles from Korea.

Dear Mr. Martorino:

In your letter dated May 8, 2007, on behalf of Barefoot Science Group Marketing Inc., you requested a tariff classification ruling for removable insoles identified and described as “foot strengthening system insoles.” You provided descriptive literature along with pictorial representations, but no actual samples.

The “Arch Activation Foot Strengthening System” insoles are said to be made of different densities of molded to shape EVA rubber/plastic materials with high wear areas reinforced, they have a top layer of nylon textile fabric sheeting and they also include specially sized and shaped, snap-in neoprene and/or TPR rubber/plastic inserts that are meant to support the arch and to cushion, strengthen and brace the foot. These specially designed footwear insoles come in sized pairs, with a series of 5 to 7 levels of progressively firmer foot strengthening rubber/plastic inserts included. The rubber/plastic inserts fit snugly into a domed arch portion on the insoles and they are intended to be used in a systematic way, starting with soft and pliant and progressing up the levels to medium and to firm.

The applicable subheading for the “Foot Strengthening System” insoles will be 6406.99.3060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of footwear; other; removable insoles, heel cushions and similar articles; of rubber or plastics. The rate of duty will be 5.3% ad valorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Richard Foley at 646-733-3042.


Robert B. Swierupski

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