CLA-2-40:OT:RR:NC:N4:421

Ms. Andrea Judy
C.H. Robinson International, Inc.
4969 Centre Pointe Drive, Suite 103
North Charleston, SC 29418

RE: The tariff classification of foot traction devices from China

Dear Ms. Judy:

In your letter dated March 17, 2011, on behalf of Implus Footcare LLC, you requested a tariff classification ruling.

Two samples of traction devices were provided with your letter. The “Skitrax” are designed for use with alpine ski boots. They are roughly sole-shaped coverings composed of styrene butadiene rubber (SBR) that stretch to fit over the bottom of the ski boot from toe to heel. They protect the soles when the user is walking on surfaces other than snow, e.g., on sidewalks and parking lots, and they promote a natural walking motion in the ski boots. The highly patterned bottom surface provides increased traction on ice and snow. The Skitrax are packaged two to a retail carton. A small carry bag is included.

The “Yaktrax XTR Extreme Outdoor Traction” devices are designed to be slipped onto boots or other footwear to provide increased traction. They are composed of natural rubber and have steel chains and spikes. The rubber framework stretches to adapt to most types of footwear for a secure fit. The high strength steel spikes and chains are designed to resist rust and abrasion. The essential character is imparted by the steel spikes, which bite into the snow or ice to provide the improved traction. The devices are sold in pairs. A small carry bag is included.

The applicable subheading for the Skitrax will be 4016.99.6050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber, other. The rate of duty will be 2.5 percent ad valorem.

The applicable subheading for the Yaktrax XTR Extreme Outdoor Traction devices will be 7326.90.8588, HTSUS, which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.

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 Joan Mazzola at (646) 733-3023.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division