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NY 868186


NOVEMBER 5, 1991

CLA-2-64:S:N:N3:D 346SM 868186

CATEGORY: CLASSIFICATION

TARIFF NO.: 6406.99.6000

Ms. Lori Olsen
Worldlink International
11677 Wayne Road, Suite 110
Romulus, MI 48174

RE: The tariff classification of shoe accessories from Germany.

Dear Ms. Olsen:

In your letter dated October 1, 1991, received here October 24, 1991, for Cadillac Shoe Products, you requested a tariff classification ruling.

You describe the items as follows:

"1) Item name: Leather Heel Grips.
Made of: Sheepskin Leather with adhesive backing.

Use: Shoe product used to prevent slipping and rubbing at heel of shoes.
HTSUS # for classification and duty:
4205.00.80008

2) Item name: Insoles.
Made of: Sheepskin Leather.
Use: To be used inside shoes for odor absorbency, cushion and keep feet cool and comfortable in shoes.
HTSUS # for classification and duty:
4205.00.80008

3) Item name: Comfort Cushions
Made of: Sheepskin Leather and Rubber
Insert/Center.
Use: Used in shoes to relieve pressure and discomfort of high heels and prevent foot from sliding in shoe.
HTSUS # for classification and duty:
4205.00.80008

4) Item name: Heel Comforters and Halter Cushions Set.
Made of: Sheepskin Leather and Rubber
Insert/Center.
Use: Used in shoes to relieve discomfort and prevent foot from sliding in shoe. Sold as single item set.
HTSUS: for classification and duty:
4205.00.80008
5) Item name: Tacco Slip.
Made of: Sheepskin Leather
Use: Used in shoes to relieve foot discomfort, protect heels and stockings.
HTSUS # for classification and duty:
4205.00.80008"

Based upon the above and upon the Cadillac "Foot Care" sheet, which you supplied we note:

1. In all cases the wool has been removed from the sheepskin.

2. Either the leather portion of the item provides its essential character or neither the leather portion nor the rubber and/or plastic portion does so by itself. We note that the "of leather" description appears after the "of rubber or plastics" description, in HTS 6406.99.

The applicable subheading for all five items will be 6406.99.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for removable insoles, heel cushions and similar articles which are essentially of leather. The rate of duty will be 5 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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