By Martina Kao    Photo：CANVA

Over the past decade, Vietnam has become one of the world’s most important footwear manufacturing bases. In 2024 alone, the United States imported hundreds of millions of pairs of shoes from Vietnam, and in the sports footwear segment, Vietnam accounts for a very significant share of total U.S. import volume and value.

At the same time, the trade and tariff environment has changed substantially. Under the latest 2025 U.S.–Vietnam trade framework, most goods of Vietnamese origin exported to the U.S. (including footwear) are subject to a reciprocal tariff of around 20%. If a shipment is determined to consist of third-country goods that have only undergone minimal processing or simple transshipment in Vietnam—so-called “origin-washing”—a 40% rate may apply; the actual rate will still depend on the product and other applicable measures.

For U.S. buyers, this means one thing:
The way your factories handle classification, origin and compliance—in product design, manufacturing and documentation—will directly determine your landed cost and risk profile.

This article focuses on footwear shipped from Vietnam to the United States under HS 6401–6404, and summarizes the key points U.S. sourcing and supply chain teams should understand.

I. What Do HS 6401–6404 Actually Cover?

U.S. import declarations ultimately use 8- or 10-digit HTSUS codes, but the starting point is understanding the logic of the 4-digit “families” under Chapter 64. In practical, simplified terms:

• HS 6401 – Waterproof footwear
  Footwear with outer soles and uppers of rubber or plastics, designed to be waterproof—for example rain boots and certain industrial waterproof boots.

• HS 6402 – Other rubber/plastic footwear
  Footwear where the outer sole and upper are primarily rubber or plastics, but which does not meet the HS 6401 definition of waterproof footwear—for example many one-piece molded sandals, slides and clogs.

• HS 6403 – Leather-upper footwear
  Footwear with uppers mainly of natural or composition leather (outer soles may be rubber, plastics or leather). Traditional dress shoes, leather boots and most leather casual shoes fall into this heading.

• HS 6404 – Textile-upper footwear
  Footwear with uppers of textile materials (woven fabrics, knit fabrics, mesh, etc.), usually with rubber or plastic outer soles. Most sports shoes, knit running shoes and fabric casual shoes are classified under 6404.

Within these broad headings, the HTSUS further breaks codes and duty rates down by:

• gender (men’s / women’s / other),
• type (sports footwear vs other),
• value per pair, and
• special features such as protective toe caps or metal plates.

For U.S. buyers, the implication is clear: how you specify materials and intended use at the design stage, and how those details are described in your documents, will directly determine the HTS code and the actual duty rate applied to each style.

II. Children’s Footwear and Chemical Compliance: Risks You Cannot Ignore

For adult footwear, U.S. chemical regulations are important but generally manageable. For children’s footwear, these requirements become hard gates you simply cannot bypass.

Two major regulatory frameworks are critical:

1. CPSIA and Lead Limits for Children’s Products

The U.S. Consumer Product Safety Improvement Act (CPSIA) sets strict lead limits for children’s products, including footwear intended for children 12 and under. In principle:

• For all accessible components, substrates must not contain more than 100 ppm of total lead, and
• surface coatings (such as paints and similar finishes) must not exceed 90 ppm of lead.

Whenever a children’s shoe is subject to CPSIA chemical requirements (for example, lead or phthalates where applicable), it must undergo third-party testing at a CPSC-accepted laboratory, and a Children’s Product Certificate (CPC) must be issued referencing the applicable rules and test results.

2. Phthalates

Under CPSIA, phthalate limits legally apply primarily to children’s toys and “child care articles”—that is, products designed to facilitate sleeping, feeding, sucking or teething for young children. Ordinary footwear does not automatically fall within these definitions.

However, many major retailers and brands, as a matter of risk management, voluntarily extend “no certain phthalates allowed” requirements to all children’s footwear materials in their vendor manuals. This is industry practice and brand policy, not a direct statutory requirement, and is intended to avoid disputes in borderline cases.

For U.S. buyers, it is advisable to:

• Clarify with each supplier the target age group for every piece;
• Ensure your children’s footwear testing program covers lead, phthalates where applicable, and your company’s or your customers’ internal Restricted Substances List (RSL) requirements;
• Clearly define who is responsible for arranging testing, paying testing costs, and maintaining test records—especially under FOB terms, where roles and responsibilities must be agreed up front.

III. Labeling and Documentation

Under 19 U.S.C. §1304 of the U.S. federal statute governing the marking of origin of imported articles, and related regulations, all imported products must be marked in English with their country of origin in a manner that is clear, sufficiently permanent, and easy to see, so that the ultimate purchaser can identify it before purchase.

For footwear, CBP in practice generally accepts country-of-origin markings in the following locations:

• A label on the inside of the tongue or collar;
• The inside quarter or another clearly visible interior location;
• In all cases, the marking must not come off under normal wear and handling, and must be visible before purchase to be considered compliant.
• CBP typically expects both shoes in a pair to be marked, and will not accept marking only on the shoebox except in very limited circumstances.

For U.S. buyers, good practice includes:

• Requiring every style to carry a clear, durable “Made in Vietnam” (or other origin) marking;
• Ensuring that markings on the shoes, carton markings, commercial invoices and origin declarations all information consistency, to avoid discrepancies that may trigger CBP questions.

On the documentation side, your customs broker will need more than just an item number and unit price. At a minimum, for each style you should be prepared to provide:

• The primary material composition of the upper, lining and outsole;
• Whether the style is men’s, women’s or children’s, and the relevant size range;
• Whether the style is considered athletic footwear, protective/safety footwear, indoor slippers, etc.;
• The unit price per pair.

The completeness and precision of your commercial descriptions often determine whether CBP will accept your classification as filed, or issue a request for information or additional documentation. In practice, if you only provide an item number and a price, the quality of the classification is usually poor and your compliance risk goes up.

IV. Packaging, Moisture Control and Transport

From a logistics perspective, footwear classified under HS 6401–6404 shares several characteristics that directly affect U.S. buyers’ costs and risk:

1. High Volume, Relatively Low Weight

Individual shoe boxes packed into master cartons mean that for air freight, courier, or ocean LCL, volumetric weight often drives the chargeable weight rather than actual scale weight. When comparing suppliers or Incoterms (FOB / CIF, etc.), pay close attention to:

• How each carton is packed and how much empty space it contains;
• Pairs per carton, carton dimensions and actual measurements;
• Whether there is any room to reduce volume in a reasonable way without compromising the retail packaging.

2. Moisture and Mold Risk on Long Sea Voyages

Ocean shipments from Vietnam to the U.S. often pass through hot, humid regions. If factory drying times are insufficient, carton quality is poor, or containers carry residual moisture, uppers and insoles are very prone to mold and odor by the time they arrive.

More robust controls include:

• Building in adequate drying time before finished shoes are boxed;
• Using appropriate desiccants, inner bags and tissue/lining paper;
• For critical shipments, conducting pre-loading inspections or taking photos before the container is sealed.

3. Wooden Pallets and ISPM 15

If suppliers use wooden pallets or wooden crates, they must comply with ISPM 15 requirements for heat treatment or fumigation and bear a valid IPPC mark. Otherwise, U.S. authorities may require re-treatment, destruction or re-export of the shipment.

To avoid this uncertainty, many large buyers require the use of ISPM-15 compliant pallets or switch to non-wood, fumigation-free pallet materials as a standard.

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