64019900
FOOTWEAR, GAITERS AND THE LIKE; PARTS OF SUCH ARTICLES›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
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Classification and scope of CN code 640199
CN code 640199 covers other waterproof footwear of rubber or plastics not classified under subheadings 640110, 640191 or 640192. This primarily includes waterproof footwear not covering the ankle, such as beach sandals with an integral waterproof construction, rubber clogs, PVC slippers, and low-profile industrial footwear made of plastics. The classification criterion for heading 6401 is the integral waterproof construction of the sole and upper achieved through vulcanisation, injection moulding, welding or bonding that prevents water penetration. The external material of the sole and upper must consist entirely of rubber or plastics. Footwear with textile or leather elements visible on the exterior is classified under headings 6402 through 6405 of the Combined Nomenclature. Customs authorities assess the waterproof character by examining the construction method and material composition.
EU regulatory requirements for imports
Importing footwear under CN code 640199 into the European Union requires compliance with the GPSR (EU) 2023/988 on general product safety, obligating importers to verify product safety before market placement. REACH Regulation (EC No 1907/2006) governs permissible chemical substance levels, particularly phthalates (DEHP, DBP, BBP, DIBP at 0.1 percent weight limit), lead and cadmium in plastics, and PAHs in rubber compounds. Footwear must be labelled according to Directive 94/11/EC indicating the material of the upper, lining and sole. The importer is responsible for displaying their contact information on the product or packaging. CE marking is not required for standard consumer footwear without protective functions. Goods imported from third countries undergo customs controls for compliance with safety standards and intellectual property rights protection.
Practical advice for importers
Correct classification of footwear under CN code 640199 requires careful analysis of the product construction. Customs authorities pay particular attention to the integrity of the sole-upper bond. If water can penetrate through seams or joints, the product does not meet the waterproofness criterion and should be classified under heading 6402. Duty rates should be verified in TARIC or the national customs database, considering the country of origin and any applicable trade measures. Imports from countries covered by free trade agreements (Vietnam EVFTA, South Korea, Japan EPA) may qualify for preferential duty rates. The importer should maintain manufacturer technical documentation, REACH laboratory test reports, and proof of origin when claiming tariff preferences. EU customs services systematically check footwear for counterfeit goods and may detain shipments where intellectual property right infringement is suspected.
Other waterproof footwear - classification CN 6401 99
Other waterproof rubber or plastic footwear not covering the ankle, without toe-caps, under CN 6401 99 carries a 17% EU duty. This covers rubber beach sandals, plastic slippers and lightweight waterproof footwear. REACH compliance for chemical substances is required.
Frequently asked questions
What distinguishes CN code 640199 from heading 6402?
The key difference is the waterproof construction. Footwear under heading 6401 (including 640199) must have an integral waterproof sole-upper construction achieved through vulcanisation or moulding. Heading 6402 covers footwear of rubber or plastics where the sole and upper do not form an integral waterproof construction, for example where they are joined by stitching or bonding that does not ensure watertightness.
Does PVC beach footwear require REACH testing before import?
The importer is responsible for ensuring product compliance with REACH Regulation, including the restrictions in Annex XVII. For PVC footwear, the limits on phthalates (plasticisers), lead and cadmium are particularly relevant. It is recommended to conduct laboratory testing before the first delivery or obtain a test report from the manufacturer issued by an accredited laboratory confirming REACH compliance.
Is footwear under CN code 640199 subject to anti-dumping duties?
The current status of anti-dumping measures for rubber and plastic footwear under CN code 640199 must be verified in the European Commission TARIC database or the national customs system. Trade defence measures may be introduced, amended or terminated depending on anti-dumping investigation outcomes. Additional TARIC codes identifying the manufacturer and country of origin must be declared during customs clearance.
What duty applies to rubber sandals CN 6401 99?
Other waterproof rubber footwear under CN 6401 99 carries a 17% EU duty. REACH compliance required. Import VAT applies.
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