RE: The tariff classification of a women’s clog shoe from China

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364972 October 2, 2026 CLA-2-64:OT:RR:NC:N2:247 CATEGORY: Classification TARIFF NO.: 6405.90.9060 Mr. Ezra Goldman Washington Shoe Company 1101 SW 16th St., Ste. 100 Renton, WA 98057 RE: The tariff classification of a women’s clog shoe from China Dear Mr. Goldman: In your letter dated September 9, 2026, you requested a tariff classification ruling. You submitted a sample which will be retained for training purposes. The submitted sample, identified as style TS712011303H, the “Solid Garden Clog,” is a women’s closed-toe, open-heel, slip-on, lined clog-style shoe that does not cover the ankle. The upper and outer sole are joined via vulcanization or cementing and are secured with a foxing-like band. Both the upper and the outer sole are composed of molded rubber/plastics. The upper features a textile trim along the collar. The outer sole features rows of wavy tread ribs with what is said to be an application of a material “having the characteristics of leather.” You state that the application is composed of 70 percent leather, 20 percent polyurethane and 10 percent coloring agent. You also provided video and photographs to substantiate the manufacturing process of the outer sole. Our observations conclude that the application on the outer sole, consisting primarily of leather, is the majority of the outer sole which is in contact with ground during use. The applicable subheading for the style TS712011303H, the “Solid Garden Clog,” will be 6405.90.9060, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for “Other footwear: Other: Other: Other.” The general 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 Code of Federal Regulations (19 CFR 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 Michael Capanna at michael.s.capanna@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division