World Footwear


AAFA opposes CBP proposal to reclassify fashion footwear

Nov 22, 2019 United States
AAFA opposes CBP proposal to reclassify fashion footwear
The association representing the American footwear and apparel industries wrote to the Customs and Broder Protection warning for the consequences of the decision
The American Apparel & Footwear Association (AAFA) recently wrote to the office of the US Customs and Border Protection (CBP) strongly opposing the proposed revocation of rulings on certain fashion footwear.

This decision, according to the AAFA, would overturn decades of industry best practices and basic common sense and as such has urged the CBP not to classify these shoes as athletic footwear.

In the letter AAFA explained: "While fashion sneakers and high-performance athletic footwear might share some basic traits – flexible outsoles with traction, cushioned insoles, and a secure closure – the similarities stop there. The fashion sneakers in the rulings in question, and fashion sneakers overall, are not intended for athletic purposes, and there are at most only a handful of examples of fashion sneakers being used for athletic purposes. Further, it would be a mistake to wear fashion footwear for an unintended purpose because it would leave the owner at risk of injury or harm because the shoe was clearly not designed for athletic use (think of the multitude of fashion sneakers that contain heel wedges). At the same time, most owners would never even consider using fashion sneakers for athletic purposes, for fear of “destroying” the look, the style, of the shoe".

The association went further by arguing that the comfort of a is not enough to have it classified as athletic footwear, especially when the shoe "could not, would not, and should not ever be used for athletic purposes".

Another argument used to re-think the reclassification of fashion footwear is the fact that the footwear market has undergone a major evolution over the last few years with the main drivers being comfort, casualization, athleisure, and high-performance athletic footwear. "Today’s consumer ... want comfort and style, leading to immense growth in the so-called fashion sneaker category".

AAFA ends the letter with a plea: "Further, I urge CBP to engage the trade in a larger conversation on fashion versus athletic footwear. As I have referenced here, the transformation of the footwear market requires a different approach to classifying what is “athletic footwear”. We hope the discussion sparked by CBP’s proposed revocation will provide the basis for this much needed conversation".

This reaction follows a recent recommendation by CBS for the reclassification of some fashion footwear as athletic footwear, which some players in the US, namely trade groups, argue could dramatically raise the duties rate imposed on certain products.

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