&&The product are waterproof boots that are said to be designed to be worn over the shoes (overshoes). The outer sole is made of polyurethane (PU) and the upper is made of thermoplastic polyurethane (TPU). The outer sole is assembled to the upper by a gluing process.&&&&The boots cover the ankle but are not high enough to cover the knee.&&&&The upper also includes two glued plastic straps for tightening purposes and metal buttons that serve the same purpose.

&&In your application for an advance ruling, you suggested tariff classification number 6401.92.92.00. This tariff classification number is correct.&&&&According to Memorandum D10-14-37, "water footwear of heading 64.01 is footwear that keeps the foot dry. The outer soles and uppers of rubber or of plastic must be assembled in such a way as to prevent seepage of water through the shoe. Such assembly methods do not include stitching, riveting, nailing, screwing, plugging or similar processes. The uppers of waterproof footwear of heading 64.01 shall cover both sides and top of the foot, such that water cannot penetrate the surface below the upper rim, regardless of the height of the upper rim."&&&&The Style A3407 Boots PVC Waterproof fits that description.&&&&Chapter 64 accounts for "Footwear, gaiters and the like; parts of such articles", and heading 64.01 specifically for "Waterproof footwear with outer soles and uppers of rubber or of plastics, the uppers of which are neither fixed to the sole nor assembled by stitching, riveting, nailing, screwing, plugging or similar processes."&&&&Since the boots at hand are waterproof, the outer sole and upper are of plastic material, and since the upper is neither fixed to the sole nor assembled by stitching, riveting, nailing, screwing, plugging or similar processes, these boots are classified in subheading 6401.92.&&&&For all of the above, and as they are neither riding boots nor Downhill ski-boots, the Style A3407 Boots PVC Waterproof are classified under 6401.92.92.00 as "Other footwear, covering the ankle but not covering the knee, of plastic", by way of GIRs 1 and 6.