CLA-2-40:OT:RR:NC:N5:137
Sean Scarbrough
Taggart International Ltd.
2825 Lewis Speedway, Unit 108
St. Augustine, FL 32084
RE: The tariff classification of kneepads from Vietnam
Dear Mr. Scarbrough:
In your letter dated August 3, 2026, you requested a tariff classification ruling on behalf of your client, Fento
Knee Protection BV.
Product number: DF280600, The Fento Roofer, is an ergonomic knee protector designed for superior traction
on any type of roof. The kneepad has a three-layer construction. The three layers are permanently glued
together. The outer layer that comes in contact with the roofing surface is composed of a 5 mm thick molded
layer of vulcanized styrene-butadiene rubber (SBR). The middle layer is composed of a 12 mm molded
ethylene vinyl acetate foam. The inner layer is composed of 18 mm polyurethane foam that is covered with a
polyester fabric liner. The kneepads also include two adjustable straps with clips to hold the kneepads in
place.
The Fento Roofer is a composite article per General Rule of Interpretation (GRI) 3(b). The rubber outer
traction layer provides the essential character.
The applicable subheading for the kneepads will be 4016.99.6050, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber: other: other:
other: other: other: other. The general rate of duty will be 2.5 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 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 Christina Allen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division