CBP Ruling N325374 — The tariff classification of footwear insoles from Thailand

Tariff classification

Headings: 6406

GRI rules applied: GRI 2(a)

Product description

You have submitted descriptive literature, photographs, and a sample of the item in question. The sample will be returned as requested. The CARESTEP Orthotic Insoles are removable insoles consisting of different molded and/or shaped rubber/plastic components. The footbed is covered with microfiber. The various rubber/plastic components provide cushion, support, and flexibility. Each insole pair comes with three pairs of rubber/plastic arch supports (inserts) that are designed to fit into the insoles. The wearer can choose a pair of low, medium, or high arch inserts depending upon the level of support desired. The F.O.B. value is $8.00 per pair. The Explanatory Notes to GRI 2(a) state the complete or finished articles presented unassembled or disassembled are to be classified in the same heading as the assembled article. Unassembled components of an article which are in excess of the number required for that article when complete, are to be classified separately. The insoles with one pair of inserts possesses the essential character of fully assembled insoles. Because the subject merchandise is packaged with three pairs of inserts, and only two of them are used at a time, the remaining two pairs of inserts are considered excess, and are classified separately. Here, the inserts happen to be classifiable in the same provision as the removable insoles.

CBP rationale

The applicable subheading for the CARESTEP Orthotic Insoles and the extra pairs of inserts will be 6406.90.3060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of footwear; other: removable insoles, heel cushions and similar articles; of rubber or plastics; other.

Full text

N325374 May 9, 2022 CLA-2-64:OT:RR:NC:N2:247 CATEGORY: Classification TARIFF NO.: 6406.90.3060 Ms. Delores Combs-Barnes Georgia Foot Care Inc 4704 Chateau Forest Way Hoschton, GA 30548 RE: The tariff classification of footwear insoles from Thailand Dear Ms. Combs-Barnes: In your letter dated April 10, 2022, you requested a tariff classification ruling. You have submitted descriptive literature, photographs, and a sample of the item in question. The sample will be returned as requested. The CARESTEP Orthotic Insoles are removable insoles consisting of different molded and/or shaped rubber/plastic components. The footbed is covered with microfiber. The various rubber/plastic components provide cushion, support, and flexibility. Each insole pair comes with three pairs of rubber/plastic arch supports (inserts) that are designed to fit into the insoles. The wearer can choose a pair of low, medium, or high arch inserts depending upon the level of support desired. The F.O.B. value is $8.00 per pair. The Explanatory Notes to GRI 2(a) state the complete or finished articles presented unassembled or disassembled are to be classified in the same heading as the assembled article. Unassembled components of an article which are in excess of the number required for that article when complete, are to be classified separately. The insoles with one pair of inserts possesses the essential character of fully assembled insoles. Because the subject merchandise is packaged with three pairs of inserts, and only two of them are used at a time, the remaining two pairs of inserts are considered excess, and are classified separately. Here, the inserts happen to be classifiable in the same provision as the removable insoles. The applicable subheading for the CARESTEP Orthotic Insoles and the extra pairs of inserts will be 6406.90.3060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of footwear; other: removable insoles, heel cushions and similar articles; of rubber or plastics; other. The rate of duty will be 5.3 percent ad valorem. 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 on World Wide Web at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Stacey Kalkines at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division

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