CLA-2-64:OT:RR:NC:N4:447

Mr. Karl F. Krueger DHL Global Forwarding 2660 20th Street Port Huron, MI 48060 RE:     The tariff classification of removable felt outer soles from China Dear Mr. Kreuger: In your letter dated December 16, 2010 you requested a tariff classification ruling on behalf of your client, Orvis Company. The submitted sample identified as style 4C61-70, is a pair of interchangeable outer soles comprised of approximately 3/8” thick felt pads cemented to plastic “foot shaped” bases. They are part of the “Korkers Omnitrax System” and are designed for the attachment to fishing wader boots to provide slip resistance. You state that although they are currently manufactured in the United States, sourcing is changing to China and that they will be marked accordingly upon importation. The special wading boots that accommodate these outer soles each have a “pocket” under the toe area of which the toe of the outer sole slips into and a “button” at the back of the heel which secures itself to a rubber heel strap with a corresponding button hole, which is attached to the heel of the outer sole. In addition to this type of interchangeable outer sole, you also request classification of the same felt outer sole, but with five 2 mm carbide studs under the ball of the foot and four 2 mm carbide studs under the heel. The style of this outer sole is 4C61-71.

The applicable subheading for both interchangeable outer soles identified as styles 4C61-70 and 4C61-71 will be 6406.99.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of footwear: not outer soles and heels, of rubber or plastics; of other materials: not of textile materials, rubber or plastics, or leather; other. The rate of duty will be Free. 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 Stacey Kalkines at (646) 733-3042. Sincerely,

Robert B. Swierupski Director National Commodity Specialist Division