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 various footwear styles from Cambodia
Dear Ms. Valenta:
In your letter dated March 4, 2026, you requested a tariff classification ruling. The submitted samples were
examined and will not be returned as requested.
Style WNSS27-DC-28124-1 is a woman’s loafer having an upper comprised of a majority polyurethane
textile and the balance in leather (less than fifty percent). The outer sole is rubber or plastics with a fine
coating of textile fibers covering most of the external surface in contact with the ground. The shoe has no
foxing or foxing-like band. The weight of the rubber/plastics components is more than ten percent of the
total weight of the shoe.
Style WNSS27-SA-28192 is a woman’s slip-on sandal. The upper is comprised of two straps. The external
surface of the straps is made up of polyester strips measuring less than five millimeters wide, which is
considered a textile for purposes of Note 1(g) to Section XI of the tariff. The wide strap has a large buckle on
the lateral side. It has a wedge shaped, jute wrapped midsole, and a wrapped footbed for comfort. The outer
sole unit is composed of multiple layers of rubber/plastics with a fine application of textile material on the
external surface facing the ground. The shoe has no foxing or foxing-like band. The weight of the
rubber/plastics components is more than ten percent of the total weight of the shoe.
The applicable subheading for style WNSS27-DC-28124-1, a woman’s loafer, and style
WNSS27-SA-28192, a woman’s slip-on sandal, 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 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 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.
Style WNSS27-ES-28204-1 is a woman’s casual slip-on shoe having a 100 percent cotton eyelet upper and a
wide lace threaded through four pairs of eyelets. The rubber/plastics outer sole has a fine coating of textile
fibers covering most of the external surface in contact with the ground. The shoe has no foxing or
foxing-like band. The weight of the rubber/plastics components is more than ten percent of the total weight
of the shoe.
The applicable subheading for the WNSS27-ES-28204-1, woman’s casual slip-on shoe, will be
6404.19.9060, 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 $12.00/pair: for women. The general rate of duty will be 9 percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. If 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division