&&These 100% polyester pink and white plush baby booties have a Velcro side closure and soles dotted with rubber/plastic traction dots.

&&Your representative has proposed classification under 6111.30.00.90. Heading 61.11 provides for “Babies' garments and clothing accessories, knitted or crocheted”. The Explanatory Notes to heading 61.11 state that only baby booties “without an outer sole glued, sewn or otherwise affixed or applied to the upper” are included under this heading. The booties do not qualify as apparel because the sole is sewn to the upper. The booties are more appropriately classified as footwear under Chapter 64. With both an upper and sole (predominately) of textile material, these booties are classified under heading 64.05, “other footwear” and more specifically under “with uppers of textile materials” subheading 6405.20.