&&According to the documentation and sample provided, the product is a shoe lacing system. It is composed of abrasion-resistant sheathed nylon wire about 1 mm in diameter, consisting of seven strands of seven stainless steel wires, plus a ratchet mechanism made mainly of plastic. This system allows a person to adjust the tension in the lace to the nearest millimetre. The product in question is usually an integral part of the components of certain shoes. In this case, however, it is imported without the shoe for the sole purpose of replacing this part if it is broken. The mechanism and lace together form a virtually inseparable complex (composite article) in which they are equally essential to the proper operation of this fastening system for shoes. The lace distributes the necessary tension throughout the shoe, to maximize the wearer’s comfort. The ratchet mechanism serves to generate and maintain this tension with a high degree of precision.

&&Respecting the scope of Legal Note 2 of Chapter 64 as well as the Explanatory Note of heading 64.06 on the subject of supplies and accessories, laces or other fastening systems "are classified in their appropriate headings" and cannot be considered as parts of shoes; hence they must be classified under their own system. The plastic ratchet mechanism is simple, being composed of indented wheels without decoupling by force which can be classified in heading 39.26. It has a rudimentary construction of moving and stationary parts and contributes to the production, modification or transmission of force in a limited manner. As a result, it does not meet the requirements of the concept of "mechanically operated" in Supplementary Note 1 of Section XVI. The sheathed lace, however, is made of steel wire under heading 73.12 which covers "stranded wire (or wire strand), obtained by closely twisting together two or more single wires, and cables and ropes of all sizes which are in turn formed by twisting such strands together". In addition, the cables of heading 73.12 may be "covered with textiles, plastics, etc." provided they remain essentially articles of steel wire.