The tariff classification of footwear from Turkey, Brazil, and China

N307801 December 10, 2019 CLA-2-64:OT:RR:NC:N2:247 CATEGORY: Classification TARIFF NO.: 6402.99.3165; 6403.99.9065; 6404.19.3960 Mr. Danny Shahrabani Azure JSD LLC PO Box 750816 Forest Hills, NY 11375 RE: The tariff classification of footwear from Turkey, Brazil, and China  Dear Mr. Shahrabani: In your letter dated November 20, 2019, you requested a tariff classification ruling. Included with your submission are photographs and descriptive literature for four styles of footwear identified as Espadrille, Bush Thong, Toe Loop Sandal Synthetic, and Toe Loop Sandal Leather. You also have provided email correspondence for clarification. The “Toe Loop Sandal Synthetic” is an open toe/open heel, below-the-ankle, ladies sandal. The upper consists of three separate rubber/plastics straps that wrap around the big toe, across the forefoot and around the ankle. The outer sole and insole are made of rubber/plastics. Rubber/plastics account for over 90 percent the external surface area. You provided an F.O.B. value of $6 per pair. This style will be imported from Brazil. The “Bush Thong” is an open toe/open heel, below-the-ankle, ladies thong sandal. The upper consists of a rubber or plastics thong which goes between the first and second toes, the outer sole and insole are made of rubber/plastics. Rubber/plastics account for over 90 percent the external surface area. You provided an F.O.B. value of $5 per pair. This style will be imported from China. The applicable subheading for the woman’s styles “Toe Loop Sandal Synthetic” and “Bush Thong” will be 6402.99.3165, Harmonized Tariff Schedule of the United States (HTSUS), which provides for footwear with outer soles and uppers of rubber or plastics: other footwear: other: other: having uppers of which over 90 percent of the external surface area (including any accessories or reinforcements) is rubber or plastics: other: other: other: for women: other. The rate of duty will be 6 percent ad valorem. The “Toe Loop Sandal Leather” is an open toe/open heel, below-the-ankle thong sandal. The upper consists of three separate cowhide leather straps that wrap around the big toe, across the forefoot, and one around the ankle. The outer sole is made of rubber/plastics. The insole is made from cowhide leather. The F.O.B. value is $9 per pair. This style will be imported from Brazil. The applicable subheading for style Toe Loop Sandal Leather, will be 6403.99.9065, HTSUS, which provides for footwear with outer soles of rubber, plastics, leather or composition leather and uppers of leather: other footwear: other: other: other: other: for other persons: Valued over $2.50 /pair: other: other: for women: other. The rate of duty will be 10 percent ad valorem. The Espadrille is a woman’s, closed toe/closed heel, below-the-ankle, slip-on espadrille style shoe. The external surface area of the upper is predominantly cotton canvas textile material. Jute material is attached to the perimeter of the upper above the outer sole. The outer sole is 100 percent rubber or plastics. Rubber/plastics account for more than 10 percent total weight of shoe. The F.O.B. value is $10 per pair. This shoe will be imported from Turkey. The applicable subheading for the Espadrille will be 6404.19.3960, HTSUS, which provides for footwear with outer soles of rubber, plastics, leather or composition leather and uppers of textile materials: footwear with outer soles of rubber or plastics: not sports footwear; footwear of the slip-on type; footwear that is not less than 10 percent by weight of rubber or plastics; other: other: for women. The rate of duty will be 37.5 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 https://hts.usitc.gov/current. 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 Stacey Kalkines at stacey.kalkines@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division