The tariff classification of various footwear styles from China and Vietnam, and washing bags from China

N359880 April 14, 2026 CLA-2-64:OT:RR:NC:N2:247 CATEGORY: Classification TARIFF NO.: 6307.90.9891, 6404.19.3730, 6404.19.3760, 6404.19.3790 Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The tariff classification of various footwear styles from China and Vietnam, and washing bags from China Dear Ms. Murrin: In your letter dated March 19, 2026, you requested a tariff classification ruling, on behalf of Rothy’s Inc., on five styles of casual footwear, each imported with a washing bag. Descriptive literature including illustrations and photographs were submitted. The five styles of Rothy’s Inc. brand slip-on shoes have closed toe/closed heels and knit textile uppers consisting of 100 percent recycled Polyethylene Terephthalate on the external surface. The outer soles consist of 100 percent rubber or plastics and textile fibers incorporated into at least 60 percent of the external surface in contact with the ground. They do not have foxing or foxing-like bands. Rubber/plastics components of each style make up 10 percent or more of the total weight of the shoes. The footwear identified as Cruiser style number 487 is a man’s espadrille-style shoe manufactured in China. Cruiser style number 315 is a woman’s Mary Jane-style shoe with a non-functional (does not open or close) strap across the top of the foot. It is imported from Vietnam. Cruiser style number 316 is a woman’s espadrille-style shoe, imported from China. Cruiser style number 485 is a child’s espadrille-style shoe, imported from Vietnam. Finally, Cruiser style number 486 is a child’s Mary Jane style shoe with a non-functional strap across the top of the foot. It is imported from Vietnam. Each footwear style is imported with an enclosed washbag that was manufactured in China. The “Cruiser Washbag,” is a textile laundry bag designed and intended to transport, store, and machine-wash the accompanying footwear. The bag is composed of 100 percent polyester knit mesh fabric. The rectangular bag is stitched along three sides with finishing binding to secure the seam and features a 100 percent cotton drawstring closure. The bag is available in two sizes: The small size measures 9 ½ inches in length by 11 inches in width; and large size measures 9 ½ inches in length by 15 inches in width. You state a laundry bag, and one pair of shoes will be packaged together and imported in a single shoebox and sold at retail as a set. In your ruling request, you proposed the Cruiser footwear and the accompanying washbag meet the set classification under GRI 3(b) and therefore should be classified under the footwear HTS. We disagree. The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of products or articles put together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).” The laundry bag and one pair of shoes fulfill the requirements of (a) and (c), above. However, we believe that they fail requirement (b). Although the footwear and washing bag are imported packaged together for retail sale, the function of each item does not join that of the other item to meet a particular need or carry out a specific activity. The shoes are intended to be worn while walking and the bag is intended to be used to hold laundry. These items are not closely related to a single purpose or activity. Each item will, therefore, be classified separately under the appropriate heading. The applicable subheading for the Cruiser Washbag will be 6307.90.9891, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The general rate of duty will be 7 percent ad valorem. The applicable subheading for the Cruiser style number 487, the man’s espadrille-style shoe, will be 6404.19.3730, 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, other, footwear of the slip-on type, that is held to the foot without the use of laces or buckles or other fasteners, the foregoing except footwear of subheading 6404.19.20 and except footwear having a foxing or foxing-like band wholly or almost wholly of rubber or plastics applied or molded at the sole and overlapping the upper: other: with uppers of textile material other than vegetable fibers and having outer soles with textile materials having the greatest surface area in contact with the ground, but not taken into account under the terms of additional U.S. note 5 to this chapter: other for men. The general rate of duty will be 12.5 percent ad valorem. The applicable subheading for the Cruiser style number 315, the woman’s Mary Jane-style shoe, and Cruiser style number 316, the woman’s espadrille-style shoe, will be 6404.19.3760, 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, other, footwear of the slip-on type, that is held to the foot without the use of laces or buckles or other fasteners, the foregoing except footwear of subheading 6404.19.20 and except footwear having a foxing or foxing-like band wholly or almost wholly of rubber or plastics applied or molded at the sole and overlapping the upper: other: with uppers of textile material other than vegetable fibers and having outer soles with textile materials having the greatest surface area in contact with the ground, but not taken into account under the terms of additional U.S. note 5 to this chapter: other for women. The general rate of duty will be 12.5 percent ad valorem. The applicable subheading for the Cruiser style number 485, the child’s espadrille-style shoe, and the Cruiser style number 486, the child’s Mary Jane style shoe, will be 6404.19.3790, 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, other, footwear of the slip-on type, that is held to the foot without the use of laces or buckles or other fasteners, the foregoing except footwear of subheading 6404.19.20 and except footwear having a foxing or foxing-like band wholly or almost wholly of rubber or plastics applied or molded at the sole and overlapping the upper: other: with uppers of textile material other than vegetable fibers and having outer soles with textile materials having the greatest surface area in contact with the ground, but not taken into account under the terms of additional U.S. note 5 to this chapter: other: other. The rate of duty will be 12.5 percent ad valorem. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Stacey Kalkines at stacey.kalkines@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division