CBP Posts Comments on Proposed Test for Footwear with Textile Soles
CBP posted the public comments filed with the agency in response to a recent proposed test to determine the tariff classification of footwear with soles of textile material. CBP released its proposed test method administering Harmonized Tariff Schedule Chapter 64, additional note 5 in the March 27 Customs Bulletin (see 13032615). The comments were posted on the agency's Freedom of Information Act library in the "Significant Records of Interest" section. CBP said it is currently reviewing the comments and "plans to prepare a decision to establish how CBP will administer Note 5" and will publish its decision in the Customs Bulletin. All of the comments are (here).
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Footwear-related trade associations voiced some concerns with the lack of details in the proposal in comments (see 13052819 and 13052925 for recent summaries of comments on the issue). Other comments not previously covered by International Trade Today were submitted by Step It Up International and ES Originals. ES Originals asked that CBP instead consider the Martindale Abrasion test, which is used by European customs authorities. CBP's proposed test, ISO 20871, is designed to test rubber and is not a fair test for textile outer soles materials, said ES Originals. Step It Up International also criticized the proposed test, saying the test doesn't provide results demonstrating that a textile material has sufficient strength and durability. "If you are going to test the outer sole to determine whether the textile material has the strength and durability normally associated with the outer sole of the footwear to which it is attached, it would require that the test encompass both the outer sole material with the textile attached and a sample with no textile attached," it said.