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FOOTWEAR, GAITERS AND THE LIKE; PARTS OF SUCH ARTICLES›Other footwear with outer soles and uppers of rubber or plastics
Other footwear - Covering the ankle
Classification and products covered by CN code 640291
CN code 640291 covers footwear covering the ankle, with outer soles and uppers of rubber or plastics, other than waterproof footwear of heading 6401, sports footwear of subheadings 640212-640219, and footwear with straps attached by plugs of subheading 640220. Typical products include urban ankle boots of plastics, PVC or polyurethane women's boots, winter boots with synthetic rubber uppers, and fashion footwear covering the ankle made from synthetic materials. Classification requires the upper to cover the ankle, with the external material of the upper and sole predominantly consisting of rubber or plastics. Footwear not covering the ankle is classified under subheading 640299. The construction does not need to be waterproof, which distinguishes code 640291 from subheading 640192. Classification considers the external surface area of the upper, not the lining material.
EU regulations governing imports
Import of footwear under CN code 640291 into the EU is subject to the GPSR (EU) 2023/988 on general consumer product safety. REACH Regulation governs chemical substance content in footwear materials, restricting phthalates in plastics, azo dyes releasing carcinogenic amines, nickel in metal decorations and fasteners contacting the wearer's skin, and dimethyl fumarate (DMF) used as an anti-mould agent. Footwear labelling must comply with Directive 94/11/EC indicating upper, lining and sole materials through pictograms or descriptions. Fashion footwear does not require CE marking. The importer is obligated to display their contact details on the product or packaging and to retain technical documentation for a period of 10 years from the date the product was placed on the market.
Import guidance and logistics
When importing footwear under CN code 640291, correct identification of the upper material is crucial. Modern synthetic materials such as polyurethane microfiber or artificial leather may visually resemble natural leather but are classified as plastics under the Combined Nomenclature. In cases of doubt regarding the material, obtaining Binding Tariff Information ruling is recommended. Duty rates for code 640291 should be checked in TARIC, taking into account the country of origin. Imports from Vietnam under EVFTA or from countries benefiting from the EU GSP system may qualify for reduced duty rates. The importer should hold REACH test reports, particularly for phthalates and DMF. EU customs authorities conduct anti-counterfeiting controls, and footwear bearing well-known brand logos requires documentation confirming the legitimate supply source and brand owner authorisation.
Ankle-covering plastic footwear - CN 6402 91
Rubber or plastic footwear covering the ankle under CN 6402 91 carries a 16.9% EU duty. This covers plastic ankle boots, mid-calf boots and trekking boots. REACH compliance required. Anti-dumping duties may apply to imports from China - verify in TARIC.
Frequently asked questions
How does footwear under CN 640291 differ from CN 640192?
The key difference is the construction. Code 640192 (heading 6401) applies to waterproof footwear with an integral sole-upper construction achieved through vulcanisation or moulding. Code 640291 (heading 6402) covers ankle-covering footwear of rubber or plastics that does not need to be waterproof. The sole and upper may be joined by stitching or bonding without ensuring watertightness.
Is polyurethane artificial leather (PU) classified as plastics?
Yes. Under the Combined Nomenclature, polyurethane artificial leather (PU leather) is treated as plastics. Footwear with uppers of synthetic PU leather is classified under heading 6402, not heading 6403 (natural leather footwear). This distinction has significant implications for the applicable duty rate and any trade defence measures.
How to avoid DMF issues when importing footwear?
Dimethyl fumarate (DMF) is prohibited in consumer products on the EU market at concentrations above 0.1 mg/kg. This substance is sometimes placed in sachets inside shoe boxes as an anti-mould agent. The importer should require written confirmation from the manufacturer that DMF is not used in the production or storage process, and commission laboratory testing at an accredited facility.
What duty applies to plastic ankle boots CN 6402 91?
Plastic ankle boots under CN 6402 91 carry a 16.9% EU duty. Anti-dumping may apply from China. Import VAT applies.
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