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64039100
FOOTWEAR, GAITERS AND THE LIKE; PARTS OF SUCH ARTICLESFootwear with outer soles of rubber, plastics, leather or composition leather and uppers of leather

Other footwear - Covering the ankle

Classification and scope of CN code 640391

CN code 640391 covers footwear with outer soles of rubber, plastics, leather or composition leather, with uppers of leather, covering the ankle, other than sports footwear and footwear with protective metal toecaps. Products classified under this subheading include men's and women's leather ankle boots, leather knee boots, leather lace-up boots, officer-style leather boots, and winter footwear with leather uppers covering the ankle. Classification requires that the leather upper covers the ankle. Footwear not covering the ankle is classified under subheadings 640351 or 640359. Natural leather includes bovine, goat, sheep, pig and other hides that have undergone tanning. Composition leather (reconstituted leather) does not qualify as leather under heading 6403. The outer sole may be made from various materials including rubber, plastics or leather.

Import regulations and legal requirements

Import of leather footwear under CN code 640391 into the EU is subject to the GPSR (EU) 2023/988 on general product safety and REACH Regulation (EC No 1907/2006). REACH restrictions for natural leather include chromium VI (maximum 3 mg/kg dry weight), formaldehyde, azo dyes releasing carcinogenic aromatic amines, per- and polyfluoroalkyl substances (PFAS) in waterproofing coatings, and residual solvents used in adhesive processes. Leather footwear imported from China has historically been subject to anti-dumping duties, and the current status must be verified in TARIC. Directive 94/11/EC requires labelling of upper, lining and sole materials. Fashion footwear does not require CE marking. The importer must display their details on the product, provide information in the language of the destination country, and retain technical documentation for 10 years.

Practical guidance for importers

When importing footwear under CN code 640391, confirming that the upper material is genuine leather is essential. Visual assessment is not always sufficient, as modern polyurethane artificial leathers can closely imitate natural leather. Customs authorities may commission laboratory testing, so the importer should hold a material certificate from the manufacturer. MFN and preferential duty rates should be verified in TARIC or the national customs database. Imports from Vietnam (EVFTA), South Korea, Japan (EPA) or GSP-eligible countries may benefit from reduced duty rates, provided a valid proof of origin is presented. The importer should commission REACH testing of natural leather, with particular focus on chromium VI and formaldehyde. Customs controls on leather footwear also include IPR verification, as luxury brand boots are frequently counterfeited products.

Leather ankle-covering boots - CN 6403 91

Leather footwear covering the ankle under CN 6403 91 carries an 8% EU duty. This covers ankle boots, knee boots and leather military boots. Premium imports from Italy, Spain and Portugal. REACH compliance for leather chemicals required.

Frequently asked questions

How is footwear with a leather upper and rubber sole classified?
Footwear with a natural leather upper and an outer sole of rubber or plastics, covering the ankle, is classified under CN code 640391, provided it is not sports footwear or safety footwear with metal toecaps. The outer sole material does not affect the heading choice within heading 6403, which allows rubber, plastics, leather or composition leather soles.
Are leather ankle boots imported from China subject to special charges?
Leather footwear from China has historically been subject to anti-dumping duties in the EU. The current status of trade measures, including any anti-dumping duties, must be checked in the European Commission TARIC system. Additional TARIC codes identifying the exporting manufacturer must be declared at customs clearance. The standard MFN duty rate should be verified before completing the transaction.
What REACH tests are most important for natural leather footwear?
The most important tests include chromium VI determination (limit 3 mg/kg), free and released formaldehyde, azo dyes releasing carcinogenic aromatic amines (22 amines listed in REACH Annex XVII), and pentachlorophenol (PCP). For waterproofed leather, PFAS content testing is additionally recommended. Testing should be performed by an ISO 17025 accredited laboratory.
What is the EU duty on leather ankle boots CN 6403 91?
Leather boots covering the ankle under CN 6403 91 carry an 8% EU duty. REACH compliance required. Import VAT applies.