CLA-2-90:OT:RR:NC:N1:105
Steven Sanders
Sanders Brokerage Services
1050 B Street - Bldg. B STE #1
P.O. Box 1983
Blaine, WA 98231
RE: The classification, country of origin and marking of a smart horse sneaker
Dear Mr. Sanders:
In your letter dated April 23, 2026, on behalf of your client, Cavallo Horse and Rider LLC, you requested a
classification, country of origin, and marking ruling on a smart horse sneaker. Descriptive literature was
provided for our review.
The item under consideration is described as the Consteed Smart Horse Sneaker, which is an advanced
diagnostic equine boot designed to detect early lameness in horses through comprehensive gait and
movement analysis. Intended for veterinarians, trainers, farriers, and rehabilitation professionals, this system
comes as a kit comprising four smart horse sneakers, a multi-connection charger, a hoof pick, and four hoof
socks. Each hoof boot integrates embedded electronic sensors, including force sensors, in the sole to record
pressure distribution and an Electronic Unit (EU) that captures 6-axis movement and acceleration values.
This data, collected directly from the horse’s hoof, is transmitted wirelessly via Bluetooth to a paired mobile
device. Utilizing a combination of force-plate technology, pressure mapping, and motion-sensor electronics,
the Consteed Smart Horse Sneaker measures ground reaction forces (measured in Newton) and processes this
information to provide real-time, quantitative insights into the horse’s gait, balance, and symmetry. This
enables the early identification of potential sources of lameness. The Consteed Smart Horse Sneaker is
specifically for diagnostic assessment and is not intended as a riding boot, protective hoof boot for turnout, or
for equine protection or hoof therapy.
The Consteed Smart Horse Sneaker is assembled from components sourced globally, including Luxembourg,
Switzerland, Austria, Indonesia, China, Italy, Liechtenstein, and Germany. Indonesia provides the hoof boot,
hoof socks, and holder. Chinese components include the ECU battery, hoof pick, magnet, and RFID label.
Italy supplies a significant portion of the system, including the electronic unit (ECU), sensors, contact
charging pin, USB-A with printed circuit board, cover plate, organ plate, case, banderole, charging cable,
quick start guide, safety regulation booklet, and various labels. From Luxembourg comes the Sensor SZ L,
which includes adhesive film, while other minor components are sourced from Switzerland. Liechtenstein
provides the sensor mat, and Austria contributes the sensor plate, including its RFID and cover plate. Finally,
Germany supplies the polyurethane coating, additional labels, and pressure equalization membranes.
The hoof boot manufacturing occurs in Indonesia starting with the injection molding of the lower hard-shell
housing from a polycarbonate and acrylonitrile butadiene styrene (PC+ABS) blend. After inspection, two flat
disc magnets are press-fitted into the housing before press-fitting the charging clip electronics with cable
assembly into the lower housing. Simultaneously, the upper charger housing is injection-molded from
customized thermoplastic elastomers (TPE). The complete charger assembly is then tested using a test
fixture, with defective parts removed.
The hoof boot is then sent to Italy along with the Chinese battery, and the sensor mat from Liechtenstein. In
Italy, the manufacturing process begins with the injection molding of fiber optics, rear covers, and front
faces, including the installation of PTFE membranes, charging pins, and magnets. After inspections,
electronics are prepared via sensor/RFID integration and plasma treated cover plates, accompanied by ECU
flashing, The next process includes the AD converter calibration, and thermal conditioning of the sensors. Per
your letter, the sensors are manufactured, programmed, and calibrated in Italy. Each of the assemblies
undergo hydraulic calibration, ultrasonic welding, and functional testing to ensure proper component
integration. The process concludes with packing, labeling, and preparing the final product for shipment.
CLASSIFICATION
In your letter, you suggest the applicable subheading for the Consteed Smart Horse Sneaker to be 9027.89.80,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatus
for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke
analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion,
surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or
light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and
apparatus: Other: Other: Other.” We disagree. The Consteed Smart Horse Sneaker is designed to use sensors
to test whether the horse’s weight is distributed properly. This in turn helps monitor the musculoskeletal
system of the horse. The device is performing more of a checking function of the mechanical and physical
properties like step accuracy, force distribution, and balance, which are not similar to the analysis of physical
properties defined by heading 9027. While gait analysis involves “physical” movement, it is not “physical
analysis” of a material’s properties in the sense intended by heading 9027. Additionally, the device is not
measuring surface tension as suggested in your letter. Measuring the way a horse moves (biomechanics) is
considered a “checking” function of mechanical movement more akin to the products classified in heading
9031. Accordingly, heading 9027 is excluded from consideration.
The applicable subheading for the Consteed Smart Horse Sneaker will be 9031.80.8085, HTSUS, which
provides for “Measuring or checking instruments, appliances and machines, not specified or included
elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and
machines: Other: Other.” The general rate of duty will be free.
ORIGIN
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Regarding the origin of the Consteed Smart Horse Sneaker, we find that the device is not able to operate until
all components are gathered and assembled in Italy. The Indonesian hoof boot and sensor mat from
Liechtenstein are transformed into a new article with name, character, and use different from the individual
components. Without the additional Italian components, including the ECU, sensors, and manufacturing, the
hoof boot would serve no purpose, and the sensor mat could not provide readings. Therefore, in our opinion,
the origin of the Consteed Smart Horse Sneaker is Italy, which is where the individual components become a
working force sensor measuring device.
MARKING
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,
indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to
indicate to the ultimate purchaser in the United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
Based on the information submitted with your letter, you suggest marking your product “Made in Italy
Engineered in Germany.” This description would be permanently affixed on both the product case sleeve as
well as the sneaker itself. With regard to the proposed marking, we note that a finding that the hoof boot was
engineered in Germany is not supported by the facts. Moreover, we find that the addition of the words
“Engineered in Germany” would make the marking misleading to the end user. Since the origin was
determined to be Italy, we find that simply marking the product “Made in Italy” would satisfy the 19 CFR
134 marking requirements.
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 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 Jason Christie at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division