Apparel & Footwear Apparel import compliance
Know each style's duty before the PO.
Fiber, construction and origin set the stack on every style. GingerOS keeps the code, the reason and each Chapter 99 line on every SKU, for every brand entity.
GingerOS- HTS
6402.99.9005- Origin
- China
- Imported by
- Footwear division, US
- Entry
- 10/06/2026
Duty stackTotal duty40%
- Base duty (MFN)
20% - Section 301, List 4A
9903.88.157.5% - Section 301, forced labor
9903.05.3112.5% - Section 122 surchargeCovered entries through July 23, 2026
9903.03.01Expired
Plus MPF 0.3464%, and HMF 0.125% by ocean
Why A rubber and plastic upper with a foxing-like band puts it in 6402.99.90 at 20%. Chinese origin adds List 4A and the 12.5% forced-labor line. Entered free from Mexico under USMCA, neither 301 line applies.
A GingerOS part record with demo data for apparel & footwear: Training shoe, rubber and plastic upper, HTS 6402.99.9005, from China. Each duty layer is listed with its rate or exemption, for a total duty of 40%.
What duty do apparel and footwear owe now?
The base rate plus every Section 301 line your origin carries; the Section 122 surcharge is gone.
Apparel and footwear carry some of the highest base rates in the tariff schedule, set by fiber, knit or woven construction and, for shoes, the upper, the sole and any foxing. Since July 24, 2026 the 10% Section 122 surcharge is gone and a Section 301 forced-labor duty applies instead: 12.5% on goods of China and Vietnam, 10% on goods of Bangladesh, Cambodia, India and Indonesia. Chinese goods on List 4A still add 7.5%. CAFTA-DR textiles and USMCA goods entered free are exempt.
Recent Policy UpdatesNotices that touch apparel and footwear
- Federal Register Notice91 FR 47318Forced-labor Section 301: 12.5% on China and Vietnam, 10% on Bangladesh and India
It stacks on China's List 4A. CAFTA-DR textiles and USMCA goods entered free are exempt.
9903.05.20 to 9903.05.84, all chaptersRead the explainer - Presidential ProclamationProclamation 11012The 10% Section 122 surcharge ends after its 150 days
Apparel entered from February 24 through July 23 carries it, unless CAFTA-DR or USMCA goods entered free; later entries do not.
9903.03.01 to 9903.03.11Read the explainer - Federal Register Notice91 FR 48913UFLPA Entity List adds 43 entities, including cotton and textile producers
Goods from listed producers are presumed barred, so cotton styles need yarn and fabric origin records wherever they are sewn.
Cotton and textile chainsRead the explainer
A Compliance Radar feed of 3 recent policy updates that touch apparel & footwear, each with its source, reference and effective date.
Does this sneaker have a foxing band?
A band at the sole that overlaps the upper moves it from 6% to 20%, and from China adds List 4A too.
Training shoe, rubber and plastic upper, rubber sole, valued at $28 a pair, made in China.
Ginger asksIs there a band applied or molded at the sole that overlaps the upper and shows from the outside?
Yes. A molded rubber band runs along the sole and overlaps the upper.
6402.99.9005HTS rate 20%
Tennis, basketball, gym and training shoes, valued over $12 a pair
From China: List 4A 7.5% and forced-labor 301 12.5%
6402.99.3115HTS rate 6%
Tennis, basketball, gym and training shoes without foxing
From China: List 4B is suspended; forced-labor 301 12.5%
Deciding rule Subheading 6402.99 sets apart footwear with foxing or a foxing-like band applied or molded at the sole and overlapping the upper; Nissho Iwai American Corp. v. United States, 143 F.3d 1470 (Fed. Cir. 1998).
A Classification Researcher conversation with demo data. Ginger asks: Is there a band applied or molded at the sole that overlaps the upper and shows from the outside? From the answer it picks HTS 6402.99.9005 over 6402.99.3115.
What lands on your sourcing team's desk?
Every style whose origin, fiber or construction changed gets a recheck, with one named next step.
GingerOSWhich of our styles now owe the forced-labor 301, and which can move to USMCA or CAFTA-DR origin?
Open rechecks3
6402.99.9005Footwear division, USForced-labor 301 on goods of ChinaRecalculate landed cost for China and MexicoRuns in Tariff CalculatorRunning6206.40.30Womenswear, USSupplier moved sewing to HondurasCompare China and Honduras landed costRuns in Parts LibraryNeeds answer6402.99.3115Footwear division, USSpec added a molded band at the soleReclassify: foxing-like band moves it to 6402.99.90Runs in Classification ResearcherReviewA GingerOS window with demo data. Someone asks: "Which of our styles now owe the forced-labor 301, and which can move to USMCA or CAFTA-DR origin?" It lists 3 open rechecks, each with the part, HTS code, trigger, tool and status.
Questions about apparel and footwear compliance
What duties apply to apparel from Vietnam or Bangladesh in October 2026?
Apparel from Vietnam pays its base rate plus a 12.5% Section 301 forced-labor duty under heading 9903.05.84, and apparel from Bangladesh pays its base rate plus 10% under 9903.05.26, on entries since July 24, 2026 (91 FR 47318). The 10% Section 122 surcharge covered entries only through July 23, 2026. USTR says textile quotas for Bangladesh, Cambodia, Indonesia and Malaysia will follow in a later notice.
Does the forced-labor Section 301 duty stack on the China List 4A tariff?
Yes. U.S. note 52(a) to Chapter 99 keeps every other subchapter III duty in place, so Chinese footwear on List 4A pays 7.5% under 9903.88.15 plus 12.5% under 9903.05.31 on top of the base rate. Sneakers under 6402.99.90.05, at a 20% base rate, land at 40% before the MPF and HMF fees (HTS 2026 Revision 20).
Are CAFTA-DR or USMCA garments exempt from the forced-labor duty?
Yes, when they enter free of duty under the agreement. Textile and apparel goods of Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras and Nicaragua entered free under CAFTA-DR claim heading 9903.05.95, and USMCA-free goods of Canada and Mexico claim 9903.05.93 or 9903.05.94 (91 FR 47318). Goods that miss the rules of origin pay the 10% duty.
Why does a foxing band change the duty on a sneaker?
Because subheading 6402.99 sets apart shoes with foxing or a foxing-like band: a rubber or plastic athletic shoe valued over $12 a pair moves from 6402.99.31 at 6% to 6402.99.90 at 20%. In Nissho Iwai American Corp. v. United States, 143 F.3d 1470 (Fed. Cir. 1998), a visible band applied or molded at the sole and overlapping the upper qualified. From China, 6402.99.31 also carries no List 4A duty.
Is footwear duty capped at 37.5%?
No. Rubber or plastic footwear valued at not over $3 a pair under 6402.99.69 carries 48%, and the $3 to $6.50 bracket carries 90 cents a pair plus 37.5% (HTS 2026 Revision 20). The line turns on upper material, outer sole, foxing, construction and value per pair, so each style needs its own 10-digit code and a record of the measurements behind it.
Does the UFLPA affect cotton apparel sewn outside China?
Yes, because the presumption follows the supply chain, not the country of assembly. On August 3, 2026, DHS added 43 entities to the UFLPA Entity List, including Henan Tongzhou Cotton Industry and Shandong Weiqiao Textile Technology (91 FR 48913). Goods produced by listed entities are presumed made with forced labor and barred, so brands need yarn and fabric origin records for every style.
What records do we need for IEEPA duties paid in 2025?
Entry-level records: entry numbers, the IEEPA Chapter 99 lines, duty amounts and liquidation dates. CBP refunds IEEPA duties only after the importer of record or its broker files a CAPE Declaration in the ACE Portal; the first phase covers unliquidated entries and entries liquidated within the last 80 days (CBP IEEPA Duty Refunds page, updated September 30, 2026). Older liquidations need a protest within 180 days of liquidation; after that the route is the Court of International Trade, and since October 6, 2026 CAPE Phase 3 processes finally liquidated entries for plaintiffs holding a reliquidation order.
What is the difference between knit and woven for tariffs?
Knit or crocheted garments classify in Chapter 61 and woven garments in Chapter 62, and that split changes both the heading and the rate. Construction is determined at entry, so getting it wrong can strand a garment at the wrong duty rate. Our HTS Classification Researcher documents the call with GRI reasoning.
