CLA-2-64:OT:RR:NC:N2 247
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The tariff classification of wading boots from South Korea
Dear Ms. Murrin:
In your letters dated October 8, 2025, and November 5, 2025, you requested a tariff classification ruling on
two styles of wading boots on behalf of Grundens USA Ltd. A description was submitted with your first
letter. Labeled diagrams showing upper material placement with corresponding percentages and a sample of
each style was submitted with your second letter. The samples will be returned.
Style 60059 “Bedrock Wading Boot” and style 60076 ‘‘Rock Armor Wading Boot” are over-the-ankle,
lace-up, boots with rubber or plastic outer soles. They are designed to be worn with neoprene socks (not
included) while fishing or hiking in, or near water. These styles are not considered “protective” against water
or cold weather as the boots are designed to allow water to enter and drain. You stated in your letter the outer
sole material overlapped the upper. Both styles were crosscut, examined, and confirmed to have
rubber/plastic outer sole material overlapping external surface area upper material by more than ¼ inch, for
the majority of the perimeter. This constitutes the presence of foxing-like bands for tariff purposes. These
styles are valued over $12 per pair.
The external surface of the upper (esau) of Style 60059 “Bedrock Wading Boot” consists of
polyurethane-coated non-woven synthetic, rubber, and polyester spandex. The external surface was
examined with magnification to verify rubber/plastics covering the majority. The constituent material of the
upper of this style is rubber or plastics. The external surface of the upper (esau) of style 60076 ‘‘Rock Armor
Wading Boot” consists of polyurethane-coated non-woven synthetic, 3D printed polyurethane printing on
polyester mesh, and polyurethane coated non-woven synthetic. The external surface was examined with
magnification to verify rubber or plastics makes up the constituent material of the upper.
You suggested a classification under subheading 6402.19.1520, Harmonized Tariff Schedule of the United
States (HTSUS), the provision for sports footwear. You state the styles have the provisions for long and
sharp features. We disagree. Although the customer may purchase additional cleats to screw into the bottom
of the boots, the boots are not imported with these optional attachments and must make a hole, or “provision”
for them. These styles are not described in chapter 64, Subheading Note 1 (a) or (b).
You suggested classification under subheading 6402.91.4010, HTSUS, the provision for footwear not having
foxing or foxing-like bands. We disagree. These styles were crosscut and found to have foxing-like bands.
You suggested classification under subheading 6404.11.9020, HTSUS, the provision for sports footwear with
uppers of textile. We disagree. The information provided and verified by physical examination found
neither style has uppers of textile nor are they sports footwear.
You suggested classification under subheading 6404.19.9030, HTSUS, the provision for footwear with
uppers of textile and valued more than $12/pair. We disagree. While we will accept the value of each style
is more than $12/pair, the constituent material of the uppers of both styles is rubber or plastics.
The applicable subheading for the Style 60059 “Bedrock Wading Boot,” and style 60076 ‘‘Rock Armor
Wading Boot,” will be 6402.91.9035, HTSUS, which provides for Other footwear with outer soles and
uppers of rubber or plastics: Other footwear: Covering the ankle: Other: Other: Other: Valued over $12/pair:
Other: For Men: Other. The general rate of duty will be 20 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 South Korea will
be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading
6402.91.9035, HTSUS, listed above.
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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division