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NY N013243

July 19, 2007



TARIFF NO.: 6404.20.4060

Mr. Fernando Ramos
Avon Products Inc.
1251 Avenue of the Americas
New York, NY 10020-1196

RE: The tariff classification of footwear from China

Dear Mr. Ramos:

In your letter dated June 18, 2007 you requested a tariff classification ruling.

The submitted sample, identified as style PP 360892 “Denim Buckle Slide,” is a women’s open-toe, open-heel, slip-on shoe with a 2-inch high heel. It has a predominately textile material upper that crosses at the wearer’s instep and includes a sewn-on belt-like plastic overlay with a metal buckle. The shoe also has a foam padded insole faced with textile and plastic, a thick paperboard midsole, a metal arch support and a leather outer sole. You have provided a component material weight percentage breakdown for this shoe, stating that it is 35.26% cardboard, 17.42% metal, 20.27% leather board, 15.9% plastic, 10.31% textile and 0.84% “thread & other.” Based on your submitted component material weight percentages, this shoe is not over 50% by weight of textile plus rubber and plastic materials. You state that the shoe will be valued at over $2.50 per pair.

The applicable subheading for the shoe identified as style PP 360892 “Denim Buckle Slide” will be 6404.20.4060 Harmonized Tariff Schedule of the United States (HTSUS), which provides for footwear, in which the upper’s external surface is predominately textile materials (excluding accessories or reinforcements); in which the outer sole is leather or composition leather; in which the shoe, by weight, is not over 50% as a total of textile plus rubber and plastics; which is valued over $2.50 per pair; for women. The rate of duty will be 10% 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/.

We are returning the sample as you requested.

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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