In ruling NY N318476 (April 7, 2021), Customs and Border Protection (CBP) discussed the classification of a shoe sanitizing mat. As mentioned in the ruling, it consists of an ethylene-vinyl acetate (EVA) foam mat, a molded plastic tray with a silicone mat affixed with screws underneath the tray, and a molded plastic reservoir with plastic screw cap. The user steps on the silicone tray, which forces cleaning solution (not included) through holes in the mat, distributing it onto the soles of the shoes. After sanitizing their shoes, the user steps on an EVA insert covered with a microfiber towel/drying mat. The mat is intended for use wherever shoe soles need to be disinfected. CBP believes that the plastic imparts the essential character over the other components, General Rule of Interpretation 3(b) noted.

CBP determined that the subject shoe sanitizing mat would be considered an article of plastic, and as it is not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9985, HTSUS, which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The general rate of duty is 5.3% ad valorem.

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.