CLA-2-64:OT:RR:NC:N2:247
Tina Fang
Steve Madden, Ltd.
52-16 Barnett Ave.
Long Island City, NY 11104
RE: The tariff classification of women’s footwear from China
Dear Ms. Fang:
In your letter dated March 31, 2025, you requested a tariff classification ruling. The samples of Steve
Madden brand footwear, included with your submission, were examined and will be returned as requested.
The merchandise identified as style ELENA1 and ELENA2 are below-the-ankle, closed toe, closed heel,
women’s shoes. The external surface area of both shoe style uppers is comprised of man-made textile
resembling faux suede around the top and sides of the foot and have faux shearling collars. The ELENA1
has two, ½-inch wide straps across the top of the foot, and the ELENA2 has a 1-inch-wide strap. The straps
are faux suede that are lined and edged with plush textile material. Functional metal buckle closures secure
the straps on the lateral sides. Both styles are completely lined with thin faux shearling material measuring
less than ½ inch uncompressed. These styles are not considered to be protective against cold weather. The
rubber/plastic outer soles measure 1 ¼-inch at the front of the shoes, and 1 ½ inches at the back.
The women’s, over-the-ankle boots, identified as styles SM-001, SMP-MM7M35, and SMP-ZXGXEK, have
man-made textile material uppers that are designed to imitate suede leather. All are thinly lined with
imitation sherpa material measuring less than ½ inch uncompressed, and have slide fastener closures on the
medial sides. The outer sole of style SMP-ZXGXEK measures 1 ¼-inch at the front and 1 ½-inch at the
back. It consists of rubber/plastics with a very light application of textile fibers on the majority of the
external surface that comes in contact with the ground. The rubber/plastics outer sole of style SM-001
measures between 1 ½-inch and 2 inches. The rubber/plastics outer sole of style SMP-MM7M35 measures
between ½-inch and 2 inches are rubber and plastics. These styles are not considered to be protective against
cold weather. The value of all these styles is stated to be between $6.50 and $12 per pair.
The applicable subheading for the footwear identified as style SMP-ZXGXEK will be 6404.19.8760,
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 textile materials: other: other: valued over $6.50
but not over $12.00/pair: other: footwear with uppers of textile material other than vegetable fibers and
having outer soles with textile materials having the greatest surface area in contact with the ground, but not
taken into account under the terms of additional U.S. note 5 to this chapter: other: for women. The rate of
duty will be 12.5 percent ad valorem.
The applicable subheading for the footwear styles identified as ELENA1, ELENA2, SM-001, and
SMP-MM7M35 will be 6404.19.8960, 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 textile
materials: footwear with outer soles of rubber or plastics: Other: Other: Valued over $6.50 but not over
$12/pair: Other: for women. The rate of duty will be 90 cents/pair + 20 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 6404.19.8760 and 6404.19.8960, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. At the time of entry, you
must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.63 in addition to
subheading 6404.19.8760 and 6404.19.8960, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6404.19.8960, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 6404.19.8960, 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
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, 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 at https://hts.usitc.gov/.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division