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NY N021207

January 9, 2008



TARIFF NO.: 6403.99.6075

Mr. John B. Pellegrini
McGuireWoods LLP
1345 Avenue of the Americas
Seventh Floor
New York, NY 10105-0106

RE: The tariff classification of footwear from China

Dear Mr. Pellegrini:

In your letter dated December 20, 2007 you requested a tariff classification ruling on behalf of Elan-Polo, Inc., for a thong style sandal identified as Style No. C2932M. The sandal has an outer sole of rubber/plastics and an upper of leather. Although the sample is not marked to indicate gender, you state that the sandal is a man’s shoe and will be marked accordingly with a label stating “Men’s size____” or the equivalent at the time of production.

The applicable subheading for Style C2932 M, labeled to indicate “Men’s size____” or the equivalent at the time of production, will be 6403.99.6075, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for footwear with outer soles of rubber/plastics and uppers of leather: other: other: for men, youths and boys, other, for men. The rate of duty will be 8.5 percent 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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