The tariff classification of Traction Overshoes/Crampons and a Camping Stool from South Korea

N362528 July 22, 2026 CLA-2-64:OT:RR:NC:N2 247 CATEGORY: Classification TARIFF NO.: 6402.99.3165; 6402.99.4960; 9401.79.0015 Tina Richards A.N. Deringer, Inc. 173 West Service Road Champlain, NY 12919 RE: The tariff classification of Traction Overshoes/Crampons and a Camping Stool from South Korea Dear Ms. Richards: In your letter dated June 24, 2026, you requested a tariff classification ruling for multiple items on behalf of your client Hillsound Equipment in Canada. In lieu of samples, a description and photographs were submitted. Item styles Flexsteps, TCP, and CY6 are unisex removable traction articles designed to be worn over shoes or boots during winter hiking and other outdoor activities. Each style, available in multiple sizes from extra-small to extra-large, is intended to provide added traction on snow- and ice-covered terrain. Each style consists of a rubber/plastics harness that secures the article over the upper portion of the shoe or boot (upper) and a traction assembly incorporating rubber/plastics footplates or pads and steel spikes (outer sole). The Flexsteps style has an additional textile hook-and-loop strap on the upper, which is stated to account for 16.7 percent of the upper’s external surface area. The styles differ in the number, size, and type of steel spikes used (stainless steel or carbon steel). The Flexsteps style features polyurethane footplates, while styles TCP and CY6 include pads positioned along the bottom of the article that appear to be made of plastic or rubber. Each style will be imported in a woven nylon carry bag with drawstring closure. The applicable subheading for the TCP and CY6 styles will be 6402.99.3165, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other 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 such as those mentioned in note 4(a) to this chapter) is rubber or plastics (except having a foxing or a foxing-like band applied or molded at the sole and overlapping the upper and except footwear designed to be worn over, or in lieu of, other footwear as a protection against water, oil, oil, grease or chemicals or cold or inclement weather: Other: Other: Other: For women: Other.” The general rate of duty will be 6 percent ad valorem. The applicable subheading for the Flexsteps style will be 6402.99.4960, HTSUS, which provides for “Other footwear with outer soles and uppers of rubber or plastics: Other footwear: Other: Other: Other: Footwear with open toes or open heels: 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 6402.99.33 and except footwear having a foxing or a foxing-like band wholly or almost wholly of rubber or plastics applied or molded at the sole and overlapping the upper: Other: Other: For women.” The general rate of duty will be 37.5 percent ad valorem. The “BTR Camping Stool,” is a portable outdoor seat constructed of a 100% nylon mesh seat foundation that is permanently affixed to an aluminum tube metal frame. A woven bungee cord constructed of a 90% natural rubber core and a 10% polyester yarn sheath cover is also permanently affixed to the seat’s metal frame. The seat is not upholstered and has no armrests or back rest. The seat will provide seating for a single individual. The seat collapses upon itself for storage and transport when not in use. The seat dimensions approximate 11” in depth, 12” in width, the legs extend from 14” - 20” in height, and the seat’s weight capacity is 240 lbs. The bungee cord is 16.54” in length and 0.08” in diameter. The portable seat is for outdoor recreation such as camping, hunting, fishing excursions, beach, concerts, and sporting events. The ruling request seeks classification of the camping stool in subheading 9401.79.0015, HTSUS. We agree. The applicable subheading for the BTR Camping Stool will be 9401.79.0015, HTSUS, which provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with metal frames: Other: Other: Outdoor: With textile covered cushions or textile seating or backing material: Other.” The general rate of duty will be free. We are unable to issue a ruling on Styles TC, TCU, and FreeStep 6 chain-style traction over shoes/crampons because we need additional information requested below: 1. Please list each style as an individual item in reference to Item 1 listed in your ruling request N362528. You have the option of resubmitting an individual ruling request for each style or you can resubmit as one listing each style as an individual item. Ensure each product and its country of origin is clearly identified. 2. Please provide a bill of material (BOM) listing the components and parts of each style. The BOM must include a breakdown of the components’ names, part numbers, quantity, cost, country of origin, and weight. When this information is available, you are welcome to resubmit a new ruling request. 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