Outer soles and heels, of rubber or plastics

CN code 640620 covers outer soles and heels of rubber or plastics, being parts of footwear classified under heading 6406. Products in this subheading include finished outer soles of vulcanised rubber, polyurethane (PU) soles, ethylene-vinyl acetate (EVA) copolymer soles, thermoplastic polyurethane (TPU) soles, plastic heels, synthetic rubber platforms, and thermoplastic rubber (TR) soles. These parts are intended for assembly into finished footwear by footwear manufacturers. Classification requires the product to be identifiable as a sole or heel based on shape, dimensions and finish. Raw rubber sheets or plastic sheets not cut to sole shape are classified under the relevant headings of Chapters 39 or 40, not under heading 6406.

Import of soles and heels under CN code 640620 into the EU is subject to REACH Regulation (EC No 1907/2006), which governs chemical substance content in rubber and plastic materials. Restrictions include polycyclic aromatic hydrocarbons (PAHs) in vulcanised rubber (limit 1 mg/kg for parts with skin contact), phthalates in soft PVC, formamide in EVA foams, and lead and cadmium in plastics. Footwear parts are not subject to Directive 94/11/EC on finished footwear labelling but must comply with REACH requirements as substances, mixtures or articles placed on the EU market. The GPSR (EU) 2023/988 may apply if parts are sold directly to consumers (e.g. replacement soles). CE marking is not required for standard footwear parts. The importer should hold material safety data sheets or REACH test reports.

When importing soles and heels under CN code 640620, the key distinction is between finished footwear parts and raw materials. Soles cut to shape, profiled and finished are classified under heading 6406, while raw rubber sheets or plastic sheets fall under Chapter 39 or 40. Duty rates may differ significantly between these classifications. Rates for code 640620 should be checked in TARIC. Preferential duty rates may apply to imports from countries covered by EU trade agreements. Import of soles and heels is often part of the supply chain for EU-based footwear manufacturers who assemble finished footwear from imported components. In such cases, the inward processing procedure may be considered, which allows suspension of duties on imported parts destined for re-export as finished footwear.

Removable outer soles and heels of rubber or plastics under CN 6406 20 carry a 5% EU duty. Used by cobblers and footwear manufacturers. Major sources: China and Italy.