CLA-2-64:OT:RR:NC:N2 247
William Maloney
Sandler, Travis & Rosenberg, P.A.
675 Third Avenue - Suite 2425
New York, NY 10017
RE: The tariff classification of traction overshoes from China, Vietnam and Korea
Dear Mr. Maloney:
In your letter dated June 3, 2025, you requested a tariff classification ruling on behalf of your client, Implus
Footcare, LLC. A sample of three products were submitted, examined, and will be returned.
The Yaktrax® brand products are designed to fit over shoes or boots to provide traction on rough, snow- or
ice-covered terrain while running, hiking, trekking, and climbing.
The sample upper of the Yaktrax® RUN™ traction overshoe consists primarily of rubber/plastics around the
perimeter of the foot. A textile webbing strap, with a hook and loop closure, is located across the top of the
foot. This strap measures approximately ¾ inch wide and is covered with rubber/plastics on its external
surface. Two nylon webbing straps measuring approximately ½ inch wide each, converge to connect the
rubber/plastics near the toes to the ¾ inch strap at the center over the foot. The external surface of the straps
is partially covered with reflective rubber/plastics. The outer sole consists of two rigid rubber /plastics pieces
set within flexible rubber/plastics under the middle and forefoot. The rigid pieces are inset with three 3mm
carbide steel studs each. The back half of the outer sole consists of flexible rubber/plastics straps wrapped
with 1.4 mm steel coils, arranged in a diamond or X pattern. This product is designed for running on packed
snow and ice. The Yaktrax® RUN™ will be imported from Vietnam.
The sample of the Yaktrax® Ascent™ has an upper consisting of a thick, stretchable rubber or plastics band
that fits securely around the upper’s sides of a boot or a shoe. Heavy-duty stainless-steel chains secure
multiple ½ inch steel spikes under the foot. There are six forward-facing spikes at the toe for digging into
slopes on steep ascents, eight under the forefoot, and three on a three-point heel piece. The product is
designed for back country excursions and wilderness exploration. It will be retail packed with a small textile
carry bag with a slide fastener closure. The Yaktrax® Ascent™ will be imported from Korea.
The Yaktrax® Summit™ is designed for hikes and backcountry treks on snow, ice, and low rock ledges. The
sample has an upper of predominantly rubber/plastics and a closure system consisting of a cord connecting
the various upper components and a dial at the back of the heel to tighten the fit. The bottom consists of
carbon steel plates forming 3/8-inch spikes that are set into four rubber or plastics pieces. Two spike plates
are positioned under the forefoot and two are positioned under the heel. They are held in place with
heavy-duty steel chains that are riveted to the upper. The Yaktrax® Summit™ will be retail packed with a
small draw-string textile pouch and imported from China.
You suggest classification of these products under subheading 9506.99.6080, Harmonized Tariff Schedule of
the United States (HTSUS), the provision for articles and equipment for general physical exercise,
gymnastics, athletics, other sports (including table-tennis) or outdoor games, not specified or included
elsewhere. We disagree. While you indicate that the items may be worn while running, trekking, or hiking,
nothing about their design or features precludes their use at other times; i.e., to provide traction on ice or
snow. More, specifically, items with uppers and outer soles worn over footwear are more specifically
provided for elsewhere.
The applicable subheading for the Yaktrax® RUN™ overshoe will be 6402.99.3165, HTSUS, which
provides for Other footwear with outer soles and uppers of rubber or plastics: Other footwear: Other: Other:
Having uppers of which over 90 percent of the external surface area (including any accessories or
reinforcements such as those mentioned in note 4 (a) to this chapter) is rubber or plastics (except footwear
having a foxing or a foxing-like band applied or molded at the sole and overlapping the upper and except
footwear designed to be worn over, or in lieu of, other footwear as a protection against water, oil, grease or
chemicals or cold or inclement weather): Other: Other: Other: For women: Other. The general rate of duty
will be 6 percent ad valorem.
The applicable subheading for the Yaktrax® Ascent™ and the Yaktrax® Summit™ will be 6405.90.9060,
HTSUS, which provides for Other footwear: Other: Other: Other. The general rate of duty will be 12.5
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 6405.90.9060, 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. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheadings
6402.99.3165 and 6405.90.9060, HTSUS, listed above.
The tariffs and additional 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/.
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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division