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 and Brazil
Dear Ms. Fang:
In your letter dated August 21, 2025, you requested a tariff classification ruling.
The TIRA style of women’s footwear is an open toe/open heel sandal. The upper is comprised of five ½-inch
straps gathered over the top of the foot with a single strap that is decorated with a gold-colored,
dome-shaped, metal ornament. Each strap consists of multiple PU strips measuring approximately 2mm
wide. (If plastic strip has an apparent width of 5 mm or less, it is considered a textile for purposes of Section
XI of the tariff. See, Note 1(g) to Section XI.) The TIRA has a padded insole and a rubber/plastics outer
sole. The outer sole has non-durable textile material covering the majority of the external surface area in
contact with the ground. Rubber/plastics components make up more than ten percent, by weight, of the total
weight of the shoe. The value of the shoe is $10/pair. The origin of this shoe will be Brazil.
The applicable subheading for the TIRA style footwear will be 6404.19.3760, 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 with open toes or open heels; Other: 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 general
rate of duty will be 12.5 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 Brazil will be
subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.09 in addition to subheading
6404.19.3760, HTSUS, listed above.
Effective August 6, 2025, Executive Order 14323 imposed additional duties on products from Brazil. At this
time, products of Brazil provided by heading 9903.01.77, except for products described in headings
9903.01.78 – 9903.01.83, will be subject to an additional ad valorem rate of duty of 40 percent. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.77, in
addition to subheading 6404.19.3760, HTSUS, listed above.
The NOEMI style of women’s footwear is a Mary Jane-styled flat shoe with a closed toe and a closed heel.
The upper consists of an open weave of folded PU strip (black) and plastic raffia (tan) backed with a clear
mesh. Each strip of PU measures approximately 3 mm wide. Each strip of plastic raffia measures 2 mm
wide. The shoe has an approximately ¾-inch wide strap, composed of woven PU strip, over the foot. The
strap is secured to the lateral side with an oval shaped, metal, functional buckle. Woven PU edging finishes
the topline. The flat rubber/plastics outer sole has non-durable textile material covering the majority of the
external surface in contact with the ground. The value of the shoe is $11/pair. The origin of this shoe will be
China.
The applicable subheading for the NOEMI style footwear 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.
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, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 subheading 6404.19.8760, 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)
Denise Faingar
Acting Director
National Commodity Specialist Division