CLA-2-64:OT:RR:NC:N2:247
Angelica Valenta
TOMS Shoes LLC
5800 Uplander Way, Suite 100
Culver City, CA 90230
RE: The tariff classification of casual shoes from Vietnam
Dear Ms. Valenta:
In your letter dated July 25, 2025, you requested a tariff classification ruling. The sample submitted will not
be returned, as requested.
The item submitted identified as the “CORDONES PLUS SNEAKER - WNSS26-SN-26840-4” is a
woman’s, slip-on, below-the-ankle, closed toe/closed heel, casual shoe. The shoe is considered “slip-on”
because the tongue is sewn to the upper via elastic gore. The upper is spread to put on and take off the shoe.
Slip-on footwear is precluded from classification as sports or athletic footwear. An optional separate lace
will be sold with the footwear. The external surface area of the upper consists of 100 percent cotton textile.
It has a rubber or plastics outer sole. The external surface area of the outer sole in contact with the ground
consists of 59.8 percent applied textile and 40.2 percent rubber or plastics. Rubber or plastics is said to make
up more than 10 percent of the total weight of the shoe. The shoe does not have a foxing or foxing-like band.
The value provided is between $6.50 and $12 per pair. Although the sample is marked “Made in China,”
you state in your letter the country of origin is Vietnam.
The applicable subheading for the “CORDONES PLUS SNEAKER - WNSS26-SN-26840-4” will be
6404.19.3660, 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: Footwear of the slip-on type, that is held to the foot without the
use of laces or buckles or other fasteners; the foregoing except footwear of subheading 6404.19.20 and
except footwear having a foxing or foxing-like band wholly or almost wholly of rubber or plastics applied or
molded at the sole and overlapping the upper: Other: With uppers of 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: For women.” The rate of duty will be 7.5 percent ad
valorem.
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 of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
6404.19.3660, 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)
James Forkan
Acting Director
National Commodity Specialist Division