The tariff classification of kneepads from Vietnam

N363957August 13, 2026CLA-2-40:OT:RR:NC:N5:137
CATEGORY: Classification
TARIFF NO.: 4016.99.6050
Sean ScarbroughTaggart International Ltd.2825 Lewis Speedway, Unit 108St. Augustine, FL 32084RE: The tariff classification of kneepads from VietnamDear Mr. Scarbrough:In your letter dated
August 3, 2026
, you requested a tariff classification ruling on behalf of your client, FentoKnee Protection BV.Product number: DF280600, The Fento Roofer, is an ergonomic knee protector designed for superior tractionon any type of roof. The kneepad has a three-layer construction. The three layers are permanently gluedtogether. The outer layer that comes in contact with the roofing surface is composed of a 5 mm thick moldedlayer of vulcanized styrene-butadiene rubber (SBR). The middle layer is composed of a 12 mm moldedethylene vinyl acetate foam. The inner layer is composed of 18 mm polyurethane foam that is covered with apolyester fabric liner. The kneepads also include two adjustable straps with clips to hold the kneepads inplace.The Fento Roofer is a composite article per General Rule of Interpretation (GRI) 3(b). The rubber outertraction layer provides the essential character.The applicable subheading for the kneepads will be 4016.99.6050, Harmonized Tariff Schedule of the UnitedStates (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 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 Christina Allen at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division