WEBVTT

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>>:  Good afternoon I am Chrissy Guth

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today's webinar is “Let’s Get Informed!” –

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Unformed/Formed Webinar.

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This is the first of the National

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Commodity Specialist Division's 2023

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webinar series."  Please be mindful that

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you will be on mute during the

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presentation.

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Therefore we ask that you please submit

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any questions you have in the chat

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feature.

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Now I would like to pass it over to

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national import specialist, Stacey

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Kalkine.

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STACEY KALKINE:  Thank you Chrissy for

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your introduction.

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I went to give a special shout out to my

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associate, Florence Franchi own because

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she prepared all these fun slides that are

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going to be used today in today's

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presentation.

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A good many of you who are out there

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already know me from various trade

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seminars and previous webinars and have

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come to my office at two '01 Barrick

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Street in Manhattan.  You're welcome to

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come by if you have questions or symbols

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or just to say high.

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Today I would like to talk to you about

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footwear for your uppers specifically

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formed and unformed upper's.  Most of you

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are very familiar with uppers and the

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differences between formed and unformed,

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but for those new to footwear, I will

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start at the very beginning.

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But first a word from my sponsor.

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And finally, because footwear importing

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can be very complicated and an importer

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may using our EE rulings module online and

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he rulings that CBP.gov.

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It is easy, fast, and free.

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If you attach a nice close-up picture of

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all angles of your footwear including the

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outer sole that touches the ground, I may

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not require a sample.

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If you're not sure, please contact me via

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e-mail and we can discuss it.

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If you fall asleep or miss something

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during this webinar, it will be posted

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along with others eventually along with

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our website.

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Also, if you could, I would like you to

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hold your questions until the end.

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If you don't get to ask your question

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today, feel free to e-mail or talk to me

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at a later date.

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Uppers.

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What are they and where are they.

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What is a formed upper?

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What is and unformed upper?  Why does it

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matter?  I will talk about this and use

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three rulings as examples and talk a

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little bit about how being formed or

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unformed when importer can determine the

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country of origin, and a little about it

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for how the uppers should be marked when

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imported.

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What is an upper?  The explanatory notes,

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General de Mack, the upper is the part of

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a shoe or boot up of the sole.

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The upper shall be considered to be that

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portion of the shoe, which covers the

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sides and top of the foot.

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The treasury decision 93-88 that gives all

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the footwear definitions states that the

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uppers the part of the shoe above the

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separate sole or that portion of the shoe,

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which covers the sides and top of the foot

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if there is no separate sole.

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In upper can cover the whole leg, thigh,

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hips, and even the chest.

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Think of fishing waiters.  Here is an easy

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example.  The black part is the upper and

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the white part is the outer sole unit.

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The tariff definition of a formed upper is

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listed in additional U.S. note 4 Chapter

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64 pair provides that for the provisions

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of sub heaven 6406.104 formed uppers cover

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uppers, with closed bottoms, which have

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been shaped by lasting, molding, or

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otherwise, but not simply by closing the

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bottom.

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The treasury decision provides that in

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general formed uppers include all items,

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which have a layer of material between

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most of the foot and the ground and which

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after lacing or buckling, if needed will

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stay on the foot if worn in the condition

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as imported and which are shaped to fit

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the human foot.

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.

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In regard to shaping by lasting, molding,

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or otherwise, an upper must have the shape

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of the foot with a portion of the upper

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bent inward toward the horizontal to be

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formed.

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In the presence of molded plastic heel

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counters, tow boxes or stiffeners, without

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a portion of the upper bent inward toward

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the horizontal, that does not necessarily

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constitute shaping and their presence

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alone does not result in classification as

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a formed upper.

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So why doesn't matter if an upper is

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formed or unformed.

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Formed uppers are classified in different

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places in the tariff, and they are usually

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more expensive to import than unformed

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upper's.

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The duty for formed uppers usually ranges

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between 6% and even $0.63 per pair plus

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26.2%.  Unformed upper's are classified in

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the 6406.10.60 through 90.

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How do we get an upper to go from not

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having the shape of the fluid to having

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the shape of a foot?

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And other words from unformed to formed?

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The most traditional and common way is by

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lasting.

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Lasting is the process of stretching,

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shaking shaping, gluing, and nailing the

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boot leather around a shoe last.

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The shoe last is a mold that represents

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the shape and size of your foot.

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The last is a foot shaped form made of

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molded plastic, carved wood, cast aluminum

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or 3D printed plastic et cetera.

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They are designed into many different

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shapes and sizes.

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You could see the shapes here for men

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women and children.  A some are for dress

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shoes.  For instance,, the pointed toll,

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high heel, or for casual shoes even

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rockclimbing shoes like the one in red.

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The word, "last" comes from the old

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English word meaning footprint.

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The last the first shoe lasts were used by

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the Greeks and Romans all the way back in

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400 BC or before I started my career at

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customs.

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On the left is a woman's short, but last.

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On the right is a woman's high heel last.

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Here are some examples of men's lasts.

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The last is critical shape and fit of a

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shoe.  It is used in all phases of the

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shoe making process and it sets the size,

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silhouette, and outline of the shoe.

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The last plays a central role for the

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entire production of the shoe.

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Here's a picture of a shoe on a last being

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worked on by a technician.

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The modern shoe last is not a replica of

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the human foot.

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It is a generalization of the human foot.

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It involves shoe makers, podiatrists, and

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kinesiologist's developing bio

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mechanically ideal shapes so foot movement

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and flexing are taken into account.

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Generally, two requirements must be met in

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order for the upper to be considered

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formed.

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The upper material must be shaped. 

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Usually shaping is done by stretching on a

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last.

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And number 2, the bottoms must be

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completely closed.

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This sample has all the necessary

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requirements for classification as a

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formed upper.

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The item has been formed by lasting into

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the shape of the foot, a portion of the

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upper has been bent inwards toward the

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horizontal, and the bottom is closed.

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To review, formed uppers are classified in

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6406 dot 10 dot zero five through 6406 dot

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10 dot 50.

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Here is an example of a form to boot upper

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that has been shaped and closed.

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Here you see the bottom of that sample.

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Sometimes, footwear is formed with the

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Strobel stitching.

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Here is the image of a Strobel sock in the

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construction of a shoe.

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In this instance since the Strobel socket

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is completely sewn to the bottom of each

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upper, and the upper has been curved or

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formed around the foot, we would say these

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uppers have closed bottoms.

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The Strobel requires the upper material to

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be sung to a fabric bottom creating a

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sock.

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The upper and bottom are joined by a

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Strobel stitch, using a Strobel machine.

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Oaf and a board will be used instead of a

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Strobel because the shoe will become more

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stable and less flexible compared with a

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Strobel lasting.

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The presence of an intact Strobel sock or

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insulating liner alone will not, by

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itself, constitute a closed bottom.

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Contrary to a formed upper, in unmolested

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is an unformed Ulster upper one that is

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completely on lasted no part of it has

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been bent or lasted inward to the

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horizontal and is only receive the limited

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shaping from simply closing at the bottom.

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It is unformed.

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Unformed uppers again classified under

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6406 dot 10 dot 60 through dot 90.

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If the whole is cut in the bottom of a

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completely formed upper, that upper does

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not have a closed bottom and therefore it

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is not a formed upper for tariff clefts

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classification purposes.

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Here is a good example of an upper that is

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not formed.

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It may have a whole that is larger than a

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nickel and/or does not have the same the

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shape of a foot.

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And unformed upper is an upper with a

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significant sized hole.  It has to be a

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nickel size or larger larger in the bottom

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layer whether or not the upper is fully

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formed or lasted.

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However, it is considered formed if the

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piece which will cover the opening is

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imported in the same shipment as the

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upper.

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This sample was the subject of rolling N.

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318 '08 zero.

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The style upper has a big hole cut through

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the insole board and waterproof booty.  A

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shank is attached, but does not block the

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whole.  That hovers just above the hole. 

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The shank has a rubber and plastic foam

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piece slightly larger than the whole which

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is attached to the shank at the heel.

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Which classification would be correct?

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Would be a formed upper or an unformed

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upper.

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Although the upper has been shaped by

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lasting, it is not considered a formed

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upper because it has a large hole cut

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through all the materials making up the

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bottom.

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The correct classification would be in

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6406 dot 10 dot 65 as unformed.

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In this example, there is an upper that

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was shaped to fit the foot by molding.

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The molding process that produced the

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upper in part is substantial shaping and

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finishing and it will stay on the foot if

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worn in the condition as inputted

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imported.

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Fully shaped by molding a portion has been

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bent inward toward the horizontal and the

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bottom is significantly closed.

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The underfoot has a three-quarter inch

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diameter round hole that has been cut out.

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The bottom of the incident upper is not

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closed because of the nickel sized hole.

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As a result, the instant upper is not a

273
00:13:33.384 --> 00:13:35.384
formed upper.

274
00:13:35.384 --> 00:13:38.174
Here are some more samples of a hole cut

275
00:13:38.174 --> 00:13:40.174
into the bottom of a completely formed

276
00:13:40.174 --> 00:13:42.174
upper.

277
00:13:42.174 --> 00:13:44.399
The uppers do not have a closed bottom and

278
00:13:45.344 --> 00:13:48.569
for classification purposes cannot be

279
00:13:48.570 --> 00:13:51.150
considered a formed upper.

280
00:13:51.150 --> 00:13:54.979
Here we see, again, a round hole

281
00:13:54.979 --> 00:13:58.798
completely through and it would also be

282
00:13:58.802 --> 00:14:00.986
considered an unformed upper.

283
00:14:00.988 --> 00:14:06.148
In this example the subjects of rolling N.

284
00:14:06.148 --> 00:14:11.306
308813 the upper has a forfeit and that

285
00:14:11.306 --> 00:14:13.305
he'll.

286
00:14:13.305 --> 00:14:16.051
It is not side lasted however.

287
00:14:16.051 --> 00:14:18.275
Has the shape of the imparted by the

288
00:14:19.629 --> 00:14:23.941
lasting forefront and heal over a sock

289
00:14:23.945 --> 00:14:27.641
lining and a rigid insole board.

290
00:14:27.644 --> 00:14:33.828
There is a large hole cut through the

291
00:14:33.828 --> 00:14:37.680
insole board near the heel.

292
00:14:37.688 --> 00:14:41.836
The issue is whether this is an it this is

293
00:14:41.838 --> 00:14:43.913
a form door unformed upper.

294
00:14:43.915 --> 00:14:46.310
The importer suggested a classification

295
00:14:46.310 --> 00:14:48.310
for an unformed upper.

296
00:14:48.310 --> 00:14:51.034
However, even though there is a large hole

297
00:14:51.036 --> 00:14:53.844
cut through the insole bore board near the

298
00:14:53.846 --> 00:14:56.303
heel the opening does not extend through

299
00:14:56.305 --> 00:14:58.762
the sock lining and is considered closed

300
00:14:58.764 --> 00:15:00.764
and a formed upper.

301
00:15:00.764 --> 00:15:03.483
Therefore the correct classification would

302
00:15:03.484 --> 00:15:09.451
be in 6406 dot 10 dot 60 for formed

303
00:15:09.452 --> 00:15:11.452
uppers.

304
00:15:11.452 --> 00:15:13.945
These also.

305
00:15:13.946 --> 00:15:17.114
Or these formed or unformed?  The criteria

306
00:15:17.117 --> 00:15:19.889
of a formed upper's last anger shaping

307
00:15:19.892 --> 00:15:22.664
toward the horizontal and it has something

308
00:15:22.667 --> 00:15:25.835
inside covering the whole that is cut out

309
00:15:25.838 --> 00:15:27.838
of the heel.

310
00:15:27.838 --> 00:15:32.201
Here is an inside view of the covering of

311
00:15:32.204 --> 00:15:34.204
the holes.

312
00:15:34.204 --> 00:15:36.858
The answer is that it is a formed upper.

313
00:15:36.858 --> 00:15:39.673
There is a closing with a lining on the

314
00:15:40.524 --> 00:15:44.031
bottom although there is a whole the

315
00:15:44.034 --> 00:15:47.040
opening is not substantial enough to

316
00:15:47.043 --> 00:15:49.047
constitute an unformed upper.

317
00:15:49.049 --> 00:15:54.242
Here in H. 165759, the underside has a few

318
00:15:54.242 --> 00:15:57.700
holes cut out of the bottom.

319
00:15:57.703 --> 00:16:00.519
This textile boot upper has one layer of

320
00:16:00.520 --> 00:16:02.984
material sewn to the top of the

321
00:16:02.984 --> 00:16:05.448
interlining.  Another outer layer is sewn

322
00:16:05.449 --> 00:16:07.561
to the bottom of the upper.

323
00:16:07.561 --> 00:16:09.731
There are holes each approximately one and

324
00:16:09.734 --> 00:16:12.524
one eighth inch in diameter cut out of the

325
00:16:12.529 --> 00:16:14.699
bottom or outer layer of the upper.

326
00:16:14.702 --> 00:16:19.390
The inner layer of the upper is complete.

327
00:16:19.390 --> 00:16:23.206
Two of these holes are covered by adhesive

328
00:16:23.210 --> 00:16:26.549
tape and the other to remain open.

329
00:16:26.552 --> 00:16:29.468
However, they were just perforations, not

330
00:16:29.470 --> 00:16:32.386
completely cut through and our flaps.

331
00:16:32.388 --> 00:16:36.500
You cannot see it from these from this

332
00:16:36.503 --> 00:16:40.615
picture, but that is what the ruling said.

333
00:16:40.619 --> 00:16:43.258
Our apartment the issue here is whether

334
00:16:43.258 --> 00:16:45.896
the instant boo uppers are classified as

335
00:16:45.896 --> 00:16:49.665
formed upper's and 64 '06 dot 10 dot 40 or

336
00:16:49.665 --> 00:16:52.304
as footwear uppers and subheading 6406 dot

337
00:16:52.305 --> 00:16:55.320
10 dot 90.  Headquarters found that the

338
00:16:55.320 --> 00:16:57.958
holes in the uppers are not substantial

339
00:16:57.958 --> 00:16:59.958
openings.

340
00:16:59.958 --> 00:17:03.885
These blue uppers are therefore formed

341
00:17:03.887 --> 00:17:10.362
uppers and under subheading 6406 dot 10.

342
00:17:10.364 --> 00:17:12.618
Another area of concern in the previous

343
00:17:12.621 --> 00:17:14.875
year with the proper marking of these

344
00:17:14.879 --> 00:17:16.879
uppers.

345
00:17:16.879 --> 00:17:19.982
Here are a few rulings and their

346
00:17:19.985 --> 00:17:24.083
explanations of the marking of uppers.

347
00:17:24.086 --> 00:17:30.470
What is the country of origin of footwear

348
00:17:30.470 --> 00:17:32.470
manufactured.

349
00:17:32.470 --> 00:17:35.286
Let me start that all over.

350
00:17:35.286 --> 00:17:37.286
What is the country of origin of footwear

351
00:17:37.286 --> 00:17:39.864
manufactured in Korea using uppers sewn in

352
00:17:39.939 --> 00:17:41.938
China.

353
00:17:41.938 --> 00:17:45.296
A man's over the ankle lace up shoe with a

354
00:17:45.296 --> 00:17:47.296
leather leather upper which was sown in

355
00:17:47.296 --> 00:17:49.296
China is completely open at the bottom and

356
00:17:49.296 --> 00:17:51.296
has not been lasted.

357
00:17:51.296 --> 00:17:54.492
The uppers will be exported to Korea where

358
00:17:55.061 --> 00:17:59.427
they will be subject of lasting and

359
00:17:59.428 --> 00:18:03.794
combined with bottoms of Korean origin to

360
00:18:03.794 --> 00:18:07.537
produce complete footwear which will be

361
00:18:07.538 --> 00:18:10.032
exported into the U.S..

362
00:18:10.032 --> 00:18:14.517
Wen now let me just.

363
00:18:14.517 --> 00:18:16.517
.

364
00:18:16.517 --> 00:18:20.841
What is the country of origin of the

365
00:18:20.841 --> 00:18:22.841
completed footwear.

366
00:18:22.841 --> 00:18:25.801
The uppers or completely open and have no

367
00:18:25.807 --> 00:18:28.894
shape, they are not complete footwear, nor

368
00:18:28.895 --> 00:18:31.982
do they have the appearance of footwear.

369
00:18:31.982 --> 00:18:35.222
Accordingly, the assembly of the uppers

370
00:18:35.222 --> 00:18:39.002
sewn in China with bottoms of Korean

371
00:18:39.002 --> 00:18:41.162
origin constitutes a substantial

372
00:18:41.163 --> 00:18:43.863
transformation of these footwear parts

373
00:18:43.863 --> 00:18:47.103
into finished footwear, which is the

374
00:18:47.103 --> 00:18:49.103
product of Korea.

375
00:18:49.103 --> 00:18:51.321
In order for a substantial transformation

376
00:18:51.321 --> 00:18:55.207
to be found, an article having a new name,

377
00:18:55.210 --> 00:18:58.238
character, and use must emerge from the

378
00:18:58.239 --> 00:19:00.239
processing.

379
00:19:00.239 --> 00:19:02.449
In this instance, the combining of the

380
00:19:02.452 --> 00:19:05.151
unformed upper's with the unattached

381
00:19:05.153 --> 00:19:07.853
bottoms in Korea, undergo additional

382
00:19:07.853 --> 00:19:10.553
processes, and constitute a substantial

383
00:19:10.554 --> 00:19:12.554
transformation.

384
00:19:12.554 --> 00:19:14.930
This resulted in a new and different

385
00:19:14.931 --> 00:19:18.767
article having a new name and use.

386
00:19:18.768 --> 00:19:27.428
That is, uppers to footwear.

387
00:19:27.429 --> 00:19:30.973
In the case of Uniroyal versus the United

388
00:19:30.973 --> 00:19:33.624
States, the court of international trade

389
00:19:33.627 --> 00:19:36.725
studied whether the addition of an out

390
00:19:36.727 --> 00:19:39.827
sole in the United States to imported

391
00:19:39.828 --> 00:19:42.481
uppers lasted in Indonesia changed the

392
00:19:42.482 --> 00:19:44.697
fundamental character of the imported

393
00:19:44.697 --> 00:19:46.697
article.

394
00:19:46.697 --> 00:19:50.185
After examining the imported upper in the

395
00:19:50.185 --> 00:19:52.185
finished shoe, the court concluded that

396
00:19:52.185 --> 00:19:54.572
the imported upper did not lose its

397
00:19:55.128 --> 00:19:58.122
distinct identity in the finished shoe,

398
00:19:58.125 --> 00:20:02.117
and to the contrary, was the very essence

399
00:20:02.121 --> 00:20:04.121
of completed footwear.

400
00:20:04.121 --> 00:20:06.962
This was so even though the imported upper

401
00:20:06.962 --> 00:20:10.300
could not be sold at retail without the

402
00:20:10.302 --> 00:20:12.808
rubber outsole being attached, and even

403
00:20:12.809 --> 00:20:15.317
though following attachment of the rubber

404
00:20:15.317 --> 00:20:18.239
outsole, the shoe was called by a

405
00:20:18.239 --> 00:20:21.160
different name, a deck issue, rather than

406
00:20:21.163 --> 00:20:23.252
an upper or a moccasin.

407
00:20:23.254 --> 00:20:26.263
The Uniroyal upper lacking an outsole

408
00:20:26.263 --> 00:20:29.774
would not be considered as having the

409
00:20:29.776 --> 00:20:32.285
essential character of completed footwear

410
00:20:32.285 --> 00:20:35.296
described in headings 6401 through 6405

411
00:20:35.296 --> 00:20:37.806
since classification as footwear under

412
00:20:37.806 --> 00:20:41.319
those headings require the presence of the

413
00:20:41.319 --> 00:20:43.325
both soles and uppers.

414
00:20:43.326 --> 00:20:50.564
The country of origin of the uppers

415
00:20:50.566 --> 00:20:52.634
remains Korea.

416
00:20:52.634 --> 00:20:56.260
Country of origin and marking of footwear

417
00:20:56.260 --> 00:20:58.260
uppers from China.

418
00:20:58.260 --> 00:21:02.986
This sample of a boot upper with the

419
00:21:02.986 --> 00:21:06.215
subject of ruling and 328994.

420
00:21:06.219 --> 00:21:09.802
The boot upper a large hole cut through

421
00:21:09.802 --> 00:21:12.038
the bottom of the upper.

422
00:21:12.040 --> 00:21:15.652
The photographs show a man's above the

423
00:21:15.654 --> 00:21:19.266
ankle full grain leather lace where upper.

424
00:21:19.267 --> 00:21:22.900
The workgroup style upper is shaped by

425
00:21:22.902 --> 00:21:26.016
lasting and sewing and includes a

426
00:21:26.018 --> 00:21:29.132
fiberboard insole and a rubber midsole.

427
00:21:29.134 --> 00:21:31.899
there is a textile label depicting an

428
00:21:31.899 --> 00:21:35.055
American flag sewn in on the lateral side

429
00:21:35.056 --> 00:21:37.056
of the foot portion.

430
00:21:37.057 --> 00:21:39.755
A nickel sized hole is cut through the

431
00:21:39.755 --> 00:21:42.865
midsole or insole in the heel section of

432
00:21:42.868 --> 00:21:44.869
the upper.

433
00:21:44.869 --> 00:21:47.657
Is shaped footwear uppers having holes

434
00:21:47.657 --> 00:21:49.696
approximately the size of a nickel or

435
00:21:49.698 --> 00:21:52.953
larger at the bottom are not considered

436
00:21:52.956 --> 00:21:54.956
closed and considered unformed.

437
00:21:54.956 --> 00:21:57.648
There is no outer sole attached to this

438
00:21:57.648 --> 00:21:59.648
unformed upper.

439
00:21:59.648 --> 00:22:02.867
It will be sourced from China.

440
00:22:02.867 --> 00:22:04.867
Further processing and finishing such as

441
00:22:04.867 --> 00:22:07.902
plugging in closing the uppers bottom, and

442
00:22:08.153 --> 00:22:11.183
attaching an outer sole, cleaning and

443
00:22:11.184 --> 00:22:14.719
packaging will be done in the U.S..

444
00:22:14.720 --> 00:22:17.936
What is the proper marking of this upper.

445
00:22:17.936 --> 00:22:21.417
While the the Code of Federal Regulations

446
00:22:21.417 --> 00:22:24.902
defines country of origin is the country

447
00:22:24.906 --> 00:22:27.894
of manufacture, production, or growth of

448
00:22:27.894 --> 00:22:31.380
any article of foreign origin and turning

449
00:22:31.381 --> 00:22:33.381
entering the United States.

450
00:22:33.381 --> 00:22:35.865
Further work or material added to an

451
00:22:35.869 --> 00:22:38.361
article in another country must effect a

452
00:22:38.364 --> 00:22:40.364
substantial transformation in order to

453
00:22:40.364 --> 00:22:42.636
render such other country at the country

454
00:22:42.642 --> 00:22:45.490
of origin within the meaning of this part.

455
00:22:45.494 --> 00:22:49.088
Based on the information submitted, noting

456
00:22:49.088 --> 00:22:51.475
the manufacturing processes including

457
00:22:51.480 --> 00:22:55.670
shaping and lasting taking place in China,

458
00:22:55.670 --> 00:23:00.459
the country of origin of the upper is

459
00:23:00.460 --> 00:23:02.461
China.

460
00:23:02.461 --> 00:23:04.584
Inasmuch as marking requirements of 19 USC

461
00:23:04.585 --> 00:23:08.113
are applicable only to articles of foreign

462
00:23:08.114 --> 00:23:11.642
origin, we agree the unformed upper's will

463
00:23:11.643 --> 00:23:14.667
be excepted from the marking requirements

464
00:23:14.668 --> 00:23:19.204
of 19 USC 1304 and should be exempt from

465
00:23:19.204 --> 00:23:21.724
any country of origin marking

466
00:23:21.725 --> 00:23:23.725
requirements.

467
00:23:23.725 --> 00:23:26.349
Of the containers in which the uppers will

468
00:23:26.352 --> 00:23:29.442
be shipped however should be clearly

469
00:23:29.445 --> 00:23:32.020
marked as made in China.

470
00:23:32.022 --> 00:23:35.638
In other words, if the uppers will be

471
00:23:35.639 --> 00:23:37.899
further processed, they individually do

472
00:23:37.899 --> 00:23:40.159
not need to be marked.

473
00:23:40.160 --> 00:23:45.529
However, the carton in which they are

474
00:23:45.531 --> 00:23:50.133
imported to the manufacturer should be

475
00:23:50.135 --> 00:23:52.135
marked.

476
00:23:52.135 --> 00:23:54.826
The story behind this sample illustrates

477
00:23:54.826 --> 00:23:58.093
the concepts of simple assembly.

478
00:23:58.095 --> 00:24:00.957
Unformed upper's are made from various

479
00:24:00.957 --> 00:24:02.957
materials originating in nonoriginating

480
00:24:02.957 --> 00:24:06.194
countries.  They are manufactured into a

481
00:24:06.198 --> 00:24:09.059
formed upper and the Dominican Republic,

482
00:24:09.060 --> 00:24:12.394
with which we have a trade program.

483
00:24:12.394 --> 00:24:15.299
Leather is imported from the United States

484
00:24:15.300 --> 00:24:18.205
to the Dominican Republic where it is

485
00:24:18.207 --> 00:24:21.112
tanned, cut to shape, and sewn together

486
00:24:21.113 --> 00:24:23.603
using thread from the U.S. Reinforcers

487
00:24:23.605 --> 00:24:26.510
imported from China are attached to the

488
00:24:26.511 --> 00:24:29.416
upper with adhesives sourced from the U.S.

489
00:24:29.418 --> 00:24:31.418
and Brazil.

490
00:24:31.418 --> 00:24:34.234
The toe box and counter are from Great

491
00:24:34.234 --> 00:24:36.234
Britain.

492
00:24:36.234 --> 00:24:38.234
At the upper is lasted and formed using

493
00:24:38.234 --> 00:24:40.234
heat and stapled to an insole board.

494
00:24:40.234 --> 00:24:43.630
The upper takes the shape of the foot in

495
00:24:43.630 --> 00:24:46.978
the Dominican republic and is considered

496
00:24:46.981 --> 00:24:50.892
to have the very essence of completed

497
00:24:50.893 --> 00:24:52.893
footwear.

498
00:24:52.893 --> 00:24:55.892
Here we have the formed upper with a

499
00:24:55.893 --> 00:24:57.893
completely closed bottom.

500
00:24:57.893 --> 00:25:00.344
This formed upper is shipped to Puerto

501
00:25:00.345 --> 00:25:02.345
Rico.

502
00:25:02.345 --> 00:25:05.146
, which is U.S. After importation, the

503
00:25:05.146 --> 00:25:08.917
outer sole is attached, trimmed, and

504
00:25:08.919 --> 00:25:12.692
polished, the footbed isn't started, and

505
00:25:12.692 --> 00:25:17.095
the shoelace and hangtags are attached and

506
00:25:17.095 --> 00:25:19.095
boxed up.

507
00:25:19.095 --> 00:25:22.080
Here's a sample of the outer sole attached

508
00:25:22.082 --> 00:25:24.082
in Puerto Rico.

509
00:25:24.082 --> 00:25:28.128
What is the proper marking of this upper.

510
00:25:28.131 --> 00:25:33.235
The attachment of the outer sole to the

511
00:25:33.235 --> 00:25:37.056
formed upper is considered assembly and

512
00:25:37.060 --> 00:25:39.060
not substantial transformation.

513
00:25:39.060 --> 00:25:42.073
Therefore, the Dominican Republic would be

514
00:25:42.075 --> 00:25:45.693
the acceptable country of origin for the

515
00:25:45.693 --> 00:25:49.828
marking of each of the formed uppers and

516
00:25:49.828 --> 00:25:52.930
each boot of the completed pair.

517
00:25:52.931 --> 00:25:56.800
As provided in Section 134.41 the country

518
00:25:56.800 --> 00:25:59.565
of origin marking is considered

519
00:25:59.565 --> 00:26:02.883
conspicuous if the ultimate purchaser in

520
00:26:02.883 --> 00:26:07.307
the U.S. can find the marking easily and

521
00:26:07.307 --> 00:26:09.517
read it without strain.

522
00:26:09.518 --> 00:26:12.350
In order to ensure that the marking is

523
00:26:12.350 --> 00:26:14.468
conspicuous, the country of origin must

524
00:26:14.471 --> 00:26:16.945
appear on each shoe in a pair.

525
00:26:16.946 --> 00:26:18.946
Not just one.

526
00:26:18.946 --> 00:26:23.501
If the marking on the tongue, inside the

527
00:26:23.501 --> 00:26:27.491
shaft, footbed, or external area is not

528
00:26:27.491 --> 00:26:30.338
legible, indelible, or permanent enough,

529
00:26:30.340 --> 00:26:32.619
hangtags may be used.

530
00:26:32.620 --> 00:26:36.638
They must be attached in a conspicuous

531
00:26:36.638 --> 00:26:41.226
place and in a manner which assures that

532
00:26:41.228 --> 00:26:44.096
unless deliberately removed, they will

533
00:26:44.097 --> 00:26:48.689
remain on the article until it reaches the

534
00:26:48.689 --> 00:26:50.689
ultimate purchaser.

535
00:26:50.689 --> 00:26:57.287
So, now I am free to take any questions

536
00:26:57.287 --> 00:27:00.595
that you may have.

537
00:27:00.597 --> 00:27:05.415
>>:  They asked if you go back to the HDS

538
00:27:05.418 --> 00:27:08.046
classification slide I believe that was

539
00:27:08.047 --> 00:27:10.047
slide 29.

540
00:27:10.047 --> 00:27:12.995
STACEY KALKINE:  29?

541
00:27:12.996 --> 00:27:16.525
Okay.

542
00:27:16.526 --> 00:27:19.374
That is slower than what I was doing.

543
00:27:19.374 --> 00:27:26.284
Here it is.  Formed uppers.  Formed uppers

544
00:27:26.287 --> 00:27:30.895
and unformed upper's are pretty close

545
00:27:30.897 --> 00:27:36.273
together in the tariff but the formed

546
00:27:36.275 --> 00:27:40.883
uppers come first they are classified

547
00:27:40.885 --> 00:27:45.493
through 64 oh 64041005 through 64061050.

548
00:27:45.495 --> 00:27:53.793
And that actually says formed uppers

549
00:27:53.793 --> 00:28:02.085
unformed upper's are classified in 6406

550
00:28:02.087 --> 00:28:15.909
dot 10 dot 60 through 6406 dot 90 dot 90.

551
00:28:15.912 --> 00:28:21.150
I am trying to see if we have any

552
00:28:21.154 --> 00:28:23.154
questions.

553
00:28:23.154 --> 00:28:28.015
Does anybody else see any questions that

554
00:28:28.018 --> 00:28:30.018
they need.

555
00:28:30.018 --> 00:28:32.101
SANDRA WALIA:  There were no other

556
00:28:32.102 --> 00:28:35.045
questions in the chat box that I can see.

557
00:28:35.045 --> 00:28:37.093
STACEY KALKINE:

558
00:28:37.093 --> 00:28:41.333
SANDRA WALIA:  They asked if you could

559
00:28:41.337 --> 00:28:43.337
show slide 23.

560
00:28:43.337 --> 00:28:53.007
STACEY KALKINE:  Slide 23.  That talks

561
00:28:53.007 --> 00:29:04.342
about the last and how it is a major

562
00:29:04.344 --> 00:29:11.901
component to all the shoe making

563
00:29:11.902 --> 00:29:13.902
processes.

564
00:29:13.902 --> 00:29:16.834
SANDRA WALIA:  What is the ruling number

565
00:29:16.838 --> 00:29:20.510
of the Dominican shoe sent to Puerto Rico.

566
00:29:20.513 --> 00:29:28.417
STACEY KALKINE:  That is near the end.

567
00:29:28.417 --> 00:29:35.007
I believe it is N324988.

568
00:29:35.007 --> 00:29:41.690
Just go to the Google cross rulings.

569
00:29:41.690 --> 00:29:52.930
You could Google formed uppers or in

570
00:29:52.930 --> 00:29:54.930
cross.

571
00:29:54.930 --> 00:29:58.135
SANDRA WALIA:  There is a question if you

572
00:29:58.142 --> 00:30:00.146
could please show slide 31.

573
00:30:00.150 --> 00:30:11.238
STACEY KALKINE:  Slide 31 coming up.

574
00:30:11.238 --> 00:30:16.721
It shows the Strobel stitching.

575
00:30:16.721 --> 00:30:20.209
Made on a Strobel machine.

576
00:30:20.209 --> 00:30:24.925
It closes the bottom of the shoe that has

577
00:30:24.926 --> 00:30:27.546
hopefully lasted toward the horizontal.

578
00:30:27.547 --> 00:30:29.547
SANDRA WALIA:  You have a question.

579
00:30:29.547 --> 00:30:33.379
If and unformed upper that has no lasting

580
00:30:33.379 --> 00:30:36.258
or shape considered leather parts of

581
00:30:36.261 --> 00:30:38.261
footwear in Chapter 42?

582
00:30:38.261 --> 00:30:40.661
STACEY KALKINE:  Yes, as in unformed upper

583
00:30:40.661 --> 00:30:42.661
if it is complete.

584
00:30:42.661 --> 00:30:46.474
If it is only part of the upper, I guess

585
00:30:46.479 --> 00:30:49.685
it would still be there, too, yes.

586
00:30:49.685 --> 00:30:51.685
Unformed upper.

587
00:30:51.685 --> 00:30:53.685
SANDRA WALIA:  Of another question.

588
00:30:53.685 --> 00:30:57.045
Kindly go over again with the individual

589
00:30:57.045 --> 00:30:59.428
paid needs to be marked with the country

590
00:30:59.428 --> 00:31:03.264
of origin and win the container just needs

591
00:31:03.265 --> 00:31:06.144
to be marked with the E.

592
00:31:06.145 --> 00:31:09.684
STACEY KALKINE:  When something is going

593
00:31:09.684 --> 00:31:13.729
to be consumed or used in manufacturing an

594
00:31:13.731 --> 00:31:17.272
article, I guess the ultimate purchaser in

595
00:31:17.272 --> 00:31:21.317
that case when it is considered like the

596
00:31:21.319 --> 00:31:24.353
factory and not the ultimate consumer,

597
00:31:24.354 --> 00:31:27.893
like the person wearing the shoe, then

598
00:31:27.894 --> 00:31:31.435
just the outer carton going to the

599
00:31:31.435 --> 00:31:33.963
manufacturer has to be marked.

600
00:31:33.964 --> 00:31:37.676
Particularly when it is going to have an

601
00:31:37.676 --> 00:31:41.388
outer sole put on or something else is

602
00:31:41.388 --> 00:31:45.561
going to happen to it that is going to

603
00:31:45.563 --> 00:31:48.346
give it another name or purpose.

604
00:31:48.347 --> 00:31:50.347
SANDRA WALIA:  Someone is asking for your

605
00:31:50.347 --> 00:31:52.347
e-mail.

606
00:31:52.347 --> 00:31:56.069
I can put that for them in the chat box I

607
00:31:56.074 --> 00:31:58.322
have it right here.

608
00:31:58.324 --> 00:32:01.708
STACEY KALKINE:  That is the next slide.

609
00:32:01.710 --> 00:32:06.038
SANDRA WALIA:  Someone is asking if you

610
00:32:06.038 --> 00:32:08.730
could please show slide 73.

611
00:32:08.738 --> 00:32:11.454
STACEY KALKINE:  I am glad you wrote the

612
00:32:11.454 --> 00:32:13.454
slide numbers down.

613
00:32:13.454 --> 00:32:15.978
That is very helpful.

614
00:32:15.985 --> 00:32:24.588
Country of origin defines the country of

615
00:32:24.589 --> 00:32:31.963
manufacture, production or growth of any

616
00:32:31.965 --> 00:32:39.339
article of foreign origin entering the

617
00:32:39.340 --> 00:32:41.340
U.S.

618
00:32:41.340 --> 00:32:44.449
SANDRA WALIA:  That is all I see at this

619
00:32:44.450 --> 00:32:46.450
time as far as questions.

620
00:32:46.450 --> 00:32:58.094
STACEY KALKINE:  If anybody needs any more

621
00:32:58.098 --> 00:33:08.339
questions answered, you can reach me at

622
00:33:08.342 --> 00:33:18.583
Stacey dot Cal Keynes at@CBP dot DHS.gov.

623
00:33:18.586 --> 00:33:23.346
Now my task is to think of the next topic.

624
00:33:23.350 --> 00:33:28.110
 If anybody can think of a topic that you

625
00:33:28.114 --> 00:33:32.874
would like to here me do next time, I will

626
00:33:32.877 --> 00:33:36.209
see if I can make that happen.

627
00:33:36.212 --> 00:33:39.308
SANDRA WALIA:  Thank you Stacey.  At this

628
00:33:39.308 --> 00:33:41.369
concludes our webinar for this afternoon.

629
00:33:41.371 --> 00:33:45.570
Thank you for joining us and enjoy the

630
00:33:45.570 --> 00:33:47.660
rest of your day.

631
00:33:47.666 --> 00:34:16.388
STACEY KALKINE:  Thank you very much.

632
00:34:20.864 --> 00:34:22.864
(CONCLUDED AT 2:07 PM)