Strange but true,
in certain cases where a textile material covers the “outermost sole” of a rubber
or plastic soled shoe, the duty rate on such imported shoe may be lower than if the
sole were without the “fuzz.”
This results
because such textile coating can move an importation of footwear from one
category, i.e., classification, to another, and with such move can come an
accompanying change in the rate of duty (and possibly one that is favorable to
the importer – think cheaper).
For anyone not well-versed in tariff-ease, all this really means is that a fuzzy bottom can cost less to import in to the US than one that is bare.
In case it is not
obvious, the “outer sole” is that part of footwear (other than an attached
heel) which, when in use, is in contact with the ground, i.e., the bottom of
the shoe.
Since a more
favorable duty rate may, at times, be obtained where footwear has an outer sole
of textile, it’s not uncommon to find importers buying footwear that has a thin
textile coating on the bottom (which can feel fuzzy) and then classifying the footwear under the
tariff number for shoes having textile on its sole in order to take advantage
of these duty savings.
Since US Customs
is in the business of collecting as much money in duties (revenue) as possible,
in an effort to curb inappropriate usage of such classifications, it routinely
requests more information on imported shipments to confirm that the textile is
actually there.
Starting this
month (Nov. 2013), US Customs has decided that the ISO 20871 test method will be
recognized in assessing the characteristics of the textile material attached to
outer soles.
This means that
when an importer is asked to provide more information (Customs Form 28) about
a textile covered sole, an analysis performed by an independent lab using
this test method (ISO 20871) should be presented.
Also, keep in mind that US Customs can always conduct its own testing when circumstances warrant it.
To learn more
about the impact of this, the newly branded US Fashion Industry Association (formerly
USITA) is having a webinar on this. More
information on the event can be found here.
Questions/comments? Post below or email me at clark.deanna@gmail.com
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