Mr. Richard R. Walker
V. Alexander & Co.
110 Tyson Blvd, Suite 202
Alcoa, TN 37701

RE: The tariff classification of footwear from China

Dear Mr. Walker:

In your letter dated September 16, 2019, you requested a tariff classification ruling on behalf of your client, Guntersville Breathables Inc. dba Frogg Toggs. You have submitted two samples identified as style # 251420C “Men’s Pilot II Wading Shoe-Cleated” and style # 251420F "Men’s Pilot II Wading Shoe-Felt." In addition, you have submitted a laboratory analysis, diagrams and photographs for both styles. Your samples will be returned.

Style # 251420C “Men’s Pilot II Wading Shoe-Cleated” is a man’s, closed toe/closed heel, above-the-ankle, lace-up, fishing wading boot. The boot measures approximately 8 inches high. The rubber/plastics outer sole incorporates thirteen separately molded fittings designed to accommodate screw-in flat metal stud attachments. According to your laboratory analysis the external surface area of the upper consists of 51.6 percent leather, 33.3 percent rubber/plastics, and 15.1 percent textile materials, excluding accessories/reinforcements. The boot features two drainage holes at the medial lower quarter and a foxing-like band.

The applicable subheading style # 251420C “Men’s Pilot II Wading Shoe-Cleated will be 6403.91.6075, Harmonized Tariff Schedule of the United States (HTSUS), which provides for footwear with outer soles of rubber, plastics, leather, or composition leather and uppers of leather: other footwear: covering the ankle: other: other: for men, youths and boys: other: other: for men: other. The rate of duty will be 8.5 percent ad valorem. Style # 251420F "Men’s Pilot II Wading Shoe-Felt” is identical to style # 251420C with the exception of the outer sole. A layer of dense felt textile, measuring approximately 10-11 mm thick, makes up the external surface area in contact with the ground. The felt provides traction on slippery surfaces during use as wading/ fishing footwear in wet, slippery conditions. The applicable subheading style # 251420F "Men’s Pilot II Wading Shoe-Felt will be 6405.10.0030, HTSUS, which provides for other footwear: with uppers of leather or composition leather. For men. The rate of duty will be 10 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6405.10.0030, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, HTSUS, in addition to subheading 6405.10.0030, HTSUS, listed above.   The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at and respectively.

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

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 [email protected]


Steven A. Mack
National Commodity Specialist Division