64042000
FOOTWEAR, GAITERS AND THE LIKE; PARTS OF SUCH ARTICLES›Footwear with outer soles of rubber, plastics, leather or composition leather and uppers of textile materials
Footwear with outer soles of leather or composition leather
Classification scope of CN code 640420
CN code 640420 covers footwear with outer soles of leather or composition leather, and uppers of textile materials. Products classified under this subheading combine traditional handcrafted leather soles with modern textile uppers, including espadrilles with leather soles, ballet shoes with leather soles and textile uppers, house slippers with leather soles and knitted uppers, and ceremonial footwear with textile uppers and leather soles. The key classification criterion is the outer sole material, which must be of leather or composition leather (reconstituted leather). The upper must be of textile materials (woven, knitted, non-woven). If the sole is of rubber or plastics, the footwear is classified under subheadings 640411 or 640419. Code 640420 covers a relatively niche footwear category, produced both in Europe (traditional craftsmanship) and Asia.
Import requirements and regulations
Import of footwear under CN code 640420 into the EU is subject to the GPSR (EU) 2023/988 and REACH Regulation (EC No 1907/2006). REACH restrictions apply to both natural leather in the sole (chromium VI at maximum 3 mg/kg, formaldehyde, azo dyes) and textile materials of the upper (azo dyes, formaldehyde in finishes). Directive 94/11/EC requires labelling of the upper material (textile), lining and sole material (leather). CE marking is not required for standard consumer footwear. The importer must ensure product safety and display their details on the product or packaging. Customs controls may include verification of sole material to confirm it is leather or composition leather. Duty rates for this code may differ from those for rubber-soled footwear, making correct identification of the sole material fiscally significant.
Practical advice for importers
Classification under CN code 640420 requires precise identification of the outer sole material. Composition leather (reconstituted leather) is classified together with natural leather for the purpose of sole material, but not for uppers. The importer should hold manufacturer material documentation confirming the sole composition. Duty rates should be checked in TARIC or the national customs database. Preferential duty rates may apply to imports from countries covered by EU trade agreements, including Vietnam (EVFTA), South Korea and Japan. A proof of origin is required to apply the preferential rate. The importer should commission REACH testing of both leather sole materials and textile upper materials. Footwear with leather soles is produced in smaller batches than rubber-soled footwear, which may result in higher per-unit laboratory testing costs.
Frequently asked questions
How to distinguish a leather outer sole from a rubber sole?
A leather outer sole has a characteristic fibrous structure visible in cross-section, is flexible, moisture-absorbent and has a natural leather smell. A rubber sole is uniform, elastic and waterproof. In cases of doubt, customs authorities may commission laboratory testing of the material. Composition leather (reconstituted leather) is an intermediate material classified together with natural leather as a sole material.
Are ballet shoes with textile uppers and leather soles classified under code 640420?
Yes. Ballet shoes with outer soles of natural leather and uppers of textile material are classified under CN code 640420. If the sole were of rubber or plastics, the shoes would be classified under code 640419 (non-sports footwear with textile upper and rubber sole).
What REACH requirements apply to leather outer soles?
Leather outer soles are subject to the same REACH restrictions as other leather components: chromium VI (maximum 3 mg/kg dry weight), formaldehyde, azo dyes releasing carcinogenic amines, and pentachlorophenol (PCP). Although the sole has limited contact with the wearer's skin, REACH provisions apply to all leather components of the product.
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