The tariff classification of boot band from China

N361710June 10, 2026CLA-2-39:OT:RR:NC:N3 348
CATEGORY: Classification
TARIFF NO.: 3926.20.9050
Lori BoulletHERA Consulting24430 S Hwy 99E, Suite ACanby, OR 97013RE: The tariff classification of boot band from ChinaDear Ms. Boullet:In your letter dated
May 21, 2026
, on behalf of your client, Grundéns USA Ltd, you requested a tariffclassification ruling. No sample was provided. Photographs were provided with the submissions.The replacement boot band, Style #60002, is a silicone band designed as a flat, continuous circular loop withuniform width and thickness. Its purpose is to allow the wearer to tuck their pants over the boot and securethem under the band.You suggested classification under subheading 4016.99.3510, Harmonized Tariff Schedule of the UnitedStates, (HTSUS), which provides for Other articles of vulcanized rubber other than hard rubber: Other:Other: Other: Of natural rubber: Other: Rubber bands or under subheading 6406.90.3060, HTSUS, whichprovides for parts of footwear; other: removable insoles, heel cushions and similar articles; of rubber orplastics; other. We disagree.In your letter you describe silicone as a rubber material. Note 4 to Chapter 40,HTSU, describes synthetic Srubber ransformed by vulcanization with sulfuras unsaturated synthetic substances which can be irreversibly tinto non-thermoplastic substances which, at a temperature between 18 and 29 degrees Centigrade, will notbreak on being extended to three times their original length and will return, after being extended to twicetheir original length, within a period of 5 minutes, to a length not greater than 1-1/2 times their originallength. Silicone is not unsaturated and thus is not cross-linkable with sulfur. Therefore, silicone is notconsidered to be rubber for tariff classification purposes.You also suggested classification under subheading 640.90.3060 HTSUS as a footwear part. It is not a6,component or part of a boot and is not classified as such in chapter 64. Nor is it similar to a gaiter assuggested. A gaiter is a protective covering that wraps around the ankle and lower leg extending over the top
of the shoe or boot. A gaiter is larger and more substantial than a boot band. ypically, a boot band is a strapTor elastic band worn around the top of a boot or shoe to keep pant legs in place or prevent them from ridingup.The applicable subheading for Style #60002 will be 3926.20.9050, (HTSUS), which provides for otherarticles of plastics and articles of other materials of headings 3901 to 3914: Articles of apparel and clothingaccessories (including gloves, mittens and mitts): Other: Other: Other. The general rate of duty will be 5percent 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 providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Rosemarie Hayward at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division