Re Classification Of Fashion Footwear In The United States May Cause Tariff Doubling.

US Customs plans to reclassify imported footwear into the United States, which may lead to a substantial increase in the tariff rate of sports shoes and will be severely criticized by brands, retailers and importers.

The US Customs and US Customs and Border Protection (CBP) proposal reclassifies women's and women's shoes (including some women's shoes with tight toe (closed-toe), closed heels (closed-heel) and ankle (below-the-ankle) shoes, and classifies them under HTSUS 6404.11.90 tax number, with an import duty of up to 20%, instead of only 9% of the non sports shoes listed under the current tax code. The ruling on previous NY N285583 and NY N299433 will be revoked to reflect the changes.

The US clothing and Footwear Association (AAFA), which opposes the plan, says it will overturn precedents, industry practices and common sense in the past decades.

Rick Helfenbein, President and chief executive of AAFA, sent a letter to the US Customs and Border Protection Office (Office of Trade, Regulations and Rulings). The footwear market has undergone significant changes over the past few years, leading to a huge growth in the so-called "sports shoes" category.

But he pointed out: "although fashion sports shoes and high-powered sneakers may have some characteristics in some respects, for example, they have a strong soft outsole, cushioning cushions, and a tight fit. "

"The controversial fashionable sports shoes and all fashionable sports shoes are not suitable for sports purposes. The shoes are obviously not designed for sports purposes. If the wearers use them in a more vigorous way, they may be at risk of injury. "

Instead, he wrote, "nowadays, consumers have shoes designed specifically for specific purposes: fashionable shoes that emphasize beauty and sports shoes for sports. It is very important to distinguish the purpose of usage. "

CBP pointed out in the proposed revocation of the decision No. 93-88 of the Ministry of Finance (Treasury Decision 93-88) that the shoes are "suitable for sports activities" because they all have the characteristics of strong grip soft outsole, cushioning buffer bottom and tight fitting. Therefore, CBP believes that this shoe should be classified as "sports shoes".

However, in HTSUS or TD 93-88, the definition of sports shoes does not exist. More importantly, almost all the shoes sold in the market today have these functional combinations - including formal shoes, casual shoes and even high-heeled shoes for women.

The letter continued, "but according to CBP's reasoning, almost all shoes sold on the market should be classified as sports shoes. "

Helfenbein concluded: "I urge CBP to withdraw the proposed withdrawal immediately, and continue to classify disputed shoes and all related sports shoes as non sports shoes. "