International Seaway Trading Corp. v. United States

69 Cust. Ct. 58, 349 F. Supp. 1019, 1972 Cust. Ct. LEXIS 2494
CourtUnited States Customs Court
DecidedSeptember 12, 1972
DocketC.D. 4375
StatusPublished
Cited by2 cases

This text of 69 Cust. Ct. 58 (International Seaway Trading Corp. v. United States) is published on Counsel Stack Legal Research, covering United States Customs Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
International Seaway Trading Corp. v. United States, 69 Cust. Ct. 58, 349 F. Supp. 1019, 1972 Cust. Ct. LEXIS 2494 (cusc 1972).

Opinion

Maletz, Judge:

This case presents the question as to the proper tariff classification of footwear imported from Hong Kong that was described on the invoice as “Basketball High Shoes”. The imported footwear was classified under item 700.60 of the Tariff Schedules of the United States as “[fjootwear (whether or not described elsewhere in this subpart) which is over 50 percent by weight of rubber or plastics * * *” and assessed with duty at the rate of 20 percent ad valorem.

Plaintiff claims that this classification is erroneous and contends that the footwear is properly dutiable at 15 percent ad valorem under item 700.70 as “[fjootwear * * * [wjith soles of material other than leather, [wjith uppers of vegetable fibers”.

The pertinent provisions of the tariff schedules read as follows:

Classified under:
Footwear (whether or not described elsewhere in this subpart) which is over 50 percent by weight of rubber or plastics or over 50 percent by weight of fibers and rubber or plastics with at least 10 percent by weight being rubber or plastics:
***** * *
Other footwear (except footwear having uppers of which over 50 percent of the exterior surface area is leather) :
'f’ H» •}» ^ $ iji
700.60 Other- 20% ad val.
Claimed under:
Footwear, with uppers of fibers:
With soles of material other than leather:
700.70 With uppers of vegetable fibers_ 15% ad val.

Schedule 4, Part 4, Subpart B:

Subpart B headnotes:
1. This subpart covers all rubber whether or not obtained, derived, or manufactured in whole or in part from any product described in part 1 of this schedule.
2. For the purposes of the tariff schedules, the term “rubber” means a substance, whether natural or synthetic, in bale, crumb, powder, latex, or other crude form, which can be vulcanized or otherwise, cross-linked, and which after cross-linking can be stretched at 68 °F. to at least three times its original length and [61]*61which, after having been stretched to twice its original length and the stress removed, returns within 5 minutes to less than 150 percent of its original length, and includes such substance whether or not containing fillers, extenders, pigments, or rubber-processing chemicals.

At a pretrial conference, the parties entered into the following stipulation:

1. The uppers are of vegetable fibers.
2. The footwear is in no part of leather.
3. The midsoles of the instant footwear contain, as components, among other things, “Natural Eubber ESS” and “Synthetic Eubber’’. That “Natural Eubber ESS” and “Synthetic Eubber” are substances, whether natural or synthetic, in bale, crumb, powder, latex, or other crude form, which can be vulcanized or otherwise cross-linked, and which after cross-linking, can be stretched at .68° F. to at least three times its original length and which, after having been stretched to twice its original length and the stress removed, returns within 5 minutes to less than 150% of its original length.
4. Both parties agree to be bound by a determination by the Customs Laboratory as to whether the vulcanized so-called iron powder midsole material can be stretched to three times its original length.1
5. Defendant’s Collective Exhibit ‘A’ [a Customs Laboratory Eeport which was received in evidence without objection] is correct in its determination of the relative weights of the respective materials insofar as they were therein determined.

The Customs Laboratory Eeport thus referred to states in relevant part:

The midsoles in their present condition (containing the iron powder) are not capable of being stretched to three times their original length. In our opinion the rubber hydrocarbon of the midsole would conform to the physical requirements of the term “rubber” as defined in Headnote 2, Subpart B, Part 4, Schedule 4 of TSUSA 1969.
The weight of each sneaker minus the lacing was found to be 272 grams (left sneaker) and 283.5 grams (right sneaker). The midsoles were found to weigh 156.5 grams (left sneaker) and 169.2 grams (right sneaker). Three tests on the midsole of the left sneaker showed an average of 89% by weight of iron and iron oxide. This is equivalent to 51.2% by weight of the left sneaker minus the lacing. Assuming 89% by weight of iron and iron oxide in the right midsole, the right sneaker minus the lacing contains 53.1% iron and iron oxide.
* * * * % * *
Three tests on the midsole of the right sneaker showed an average of 89.5% by weight of iron and iron oxide. This is equivalent to 53.4% by weight of the right sneaker minus the lacing.

[62]*62Against tbis background, the issue is whether the midsole material— which, according to the Customs Laboratory Eeport, constitutes over 50 percent by weight of the imported footwear — consists solely of “rubber” as defined in headnote 2, schedule 4, part 4, subpart B. If it does, the parties agree that the classification of the footwear under item 700.60 must be upheld. On the other hand, if, as contended by plaintiff, (1) the midsole material consists of approximately 10 percent by weight of “rubber” as defined in headnote 2 and approximately 90 percent by weight of iron powder, or (2) is a “rubber compound” but not “rubber”, the classification must fall and the protest be sustained. Thus, resolution of the present controversy turns upon the interpretation of the term “rubber” as defined in headnote 2, schedule 4, part 4, subpart B.

We turn now to the record which, in addition to the stipulated matters set out above, consists of the testimony of two witnesses called by defendant, and assorted exhibits. The first witness, Joseph H. Fischer, who was employed originally as a chemist and is now a footwear specialist with Uniroyal, Inc., a domestic manufacturer of rubber and canvas footwear and sponge rubber products, testified that he is primarily responsible for the process development of rubber compounds prior to their fabrication into rubber products; and that he has practiced in the field of rubber chemistry for 23 years.

Henry S.

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Related

International Seaway Trading Corp. v. United States
81 Cust. Ct. 92 (U.S. Customs Court, 1978)
International Seaway Trading Corp. v. United States
488 F.2d 544 (Customs and Patent Appeals, 1973)

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Bluebook (online)
69 Cust. Ct. 58, 349 F. Supp. 1019, 1972 Cust. Ct. LEXIS 2494, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-seaway-trading-corp-v-united-states-cusc-1972.