Button, Snap Fasteners, Slide Fasteners and Similar Articles

Published CBP guidance; operative status and applicability must be assessed from the retained publisher edition.

What Every Member of the
Trade Community Should Know About:
Buttons, Snap-Fasteners,
Slide Fasteners and
Similar Articles

AN INFORMED COMPLIANCE PUBLICATION
APRIL 2012

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NOTICE:

This publication is intended to provide guidance and information to the trade community.
It reflects the position on or interpretation of the applicable laws or regulations by U.S.
Customs and Border Protection (CBP) as of the date of publication, which is shown on
the front cover. It does not in any way replace or supersede those laws or regulations.
Only the latest official version of the laws or regulations is authoritative.

Publication History

First Published: February 2004
Reviewed With No Changes May 2005
Reviewed With No Changes March 2006
Reviewed With No Changes January 2008
Reviewed With No Changes March 2009
Reviewed With No Changes January 2010
Reviewed With No Changes February 2011
Reviewed With No Changes April 2012

PRINTING NOTE:

This publication was designed for electronic distribution via the CBP website
(http://www.cbp.gov) and is being distributed in a variety of formats. It was originally set
up in Microsoft Word 2003
®
. Pagination and margins in downloaded versions may vary
depending upon which word processor or printer you use. If you wish to maintain the
original settings, you may wish to download the .pdf version, which can then be printed
using the freely available Adobe Acrobat Reader
®
.

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PREFACE

On December 8, 1993, Title VI of the North American Free Trade Agreement Implementation
Act (Pub. L. 103-182, 107 Stat. 2057), also known as the Customs Modernization or “Mod” Act,
became effective. These provisions amended many sections of the Tariff Act of 1930 and
related laws.

Two new concepts that emerge from the Mod Act are “informed compliance” and “shared
responsibility,” which are premised on the idea that in order to maximize voluntary compliance
with laws and regulations of U.S. Customs and Border Protection, the trade community needs to
be clearly and completely informed of its legal obligations. Accordingly, the Mod Act imposes a
greater obligation on CBP to provide the public with improved information concerning the trade
community's rights and responsibilities under customs regulations and related laws. In addition,
both the trade and U.S. Customs and Border Protection share responsibility for carrying out
these requirements. For example, under Section 484 of the Tariff Act, as amended (19 U.S.C.
1484), the importer of record is responsible for using reasonable care to enter, classify and
determine the value of imported merchandise and to provide any other information necessary to
enable U.S. Customs and Border Protection to properly assess duties, collect accurate
statistics, and determine whether other applicable legal requirements, if any, have been met.
CBP is then responsible for fixing the final classification and value of the merchandise. An
importer of record’s failure to exercise reasonable care could delay release of the merchandise
and, in some cases, could result in the imposition of penalties.

Regulations and Rulings (RR) of the Office of International Trade has been given a major role in
meeting the informed compliance responsibilities of U.S. Customs and Border Protection. In
order to provide information to the public, CBP has issued a series of informed compliance
publications on new or revised requirements, regulations or procedures, and a variety of
classification and valuation issues.

This publication, prepared by the National Commodity Specialist Division of Regulations and
Rulings is entitled "Buttons, Snap-Fasteners, Slide Fasteners and Similar Articles.” It provides
guidance regarding the classification of these items. We sincerely hope that this material,
together with seminars and increased access to rulings of U.S. Customs and Border Protection,
will help the trade community to improve voluntary compliance with customs laws and to
understand the relevant administrative processes.

The material in this publication is provided for general information purposes only. Because
many complicated factors can be involved in customs issues, an importer may wish to obtain a
ruling under Regulations of U.S. Customs and Border Protection, 19 C.F.R. Part 177, or to
obtain advice from an expert who specializes in customs matters, for example, a licensed
customs broker, attorney or consultant.

Comments and suggestions are welcomed and should be addressed to U.S. Customs and
Border Protection, Office of International Trade, Executive Director, Regulations and Rulings,
799 9
th
Street N.W. 7
th
floor, Washington, D.C. 20229-1177.

Sandra L. Bell
Executive Director, Regulations and Rulings
Office of International Trade

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INTRODUCTION ........................................................................................ 7
Heading 9606 ............................................................................................................... 7
Heading 9607 ............................................................................................................... 9
DEFINITIONS ............................................................................................. 9
Slide Fastener .............................................................................................................. 9
Chain Scoop ................................................................................................................. 9
Plastic Filament ............................................................................................................ 9
Slider/Runner ............................................................................................................... 9
Slider Pull ..................................................................................................................... 9
ADDITIONAL INFORMATION .................................................................. 10
The Internet ................................................................................................................ 10
Customs Regulations ................................................................................................. 10
Customs Bulletin ........................................................................................................ 10
Importing into the United States ................................................................................. 11
Informed Compliance Publications ............................................................................. 11
Value Publications ...................................................................................................... 12
“Your Comments are Important” ................................................................................. 13

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INTRODUCTION

Heading 9606

Heading 9606 of the Harmonized Tariff Schedule of the United States (HTSUS) covers
buttons, snap-fasteners, studs and similar articles used for fastening or decorating
articles of apparel, household linen, etc. These articles may be made of various
materials (plastics, base metal, wood, etc.) and may contain pearls (natural or cultured),
precious or semi-precious stones, as well as precious metal or metal clad with precious
metal, provided these Chapter 71 materials are minor components of the item. Base
metals are defined in Section XV, Note 3. Precious metals are identified within Note 4
to Chapter 71 and metal clad with precious metal is defined within Note 7 to Chapter 71.
Importations of items containing pearls, bone, horn, leather or similar materials may be
subject to regulations of other agencies. Be sure to check with these other agencies,
such as the U.S. Fish and Wildlife Service, for their import requirements.

9606 Buttons, press-fasteners, snap-fasteners and press-studs,
button molds and other parts of these articles; button
blanks:
9606.10 Press-fasteners, snap-fasteners and press-studs and
parts thereof:
9606.10.40 00 Valued not over 20¢ per dozen pieces or parts
9606.10.80 00 Valued over 20¢ per dozen pieces or parts
Buttons:
9606.21 Of plastics, not covered with textile material:
9606.21.20 00 Of casein
9606.21.40 00 Of acrylic resin, of polyester resin or of both
such resins
9606.21.60 00 Other
9606.22.00 00 Of base metal, not covered with textile material
9606.29 Other:
9606.29.20 00 Of acrylic resin, of polyester resin or of both
such resins, covered with textile material
Other:
9606.29.40 00 Of pearl or shell
9606.29.60 00 Other
9606.30 Button molds and other parts of buttons; button blanks:
9606.30.40 00 Button blanks of casein
9606.30.80 00 Other

Press-fasteners, snap-fasteners and press-studs, found in subheading 9606.10,
HTSUS, would include two or more parts and would function by clicking or snapping the
pieces together. They can be attached to the garment, item or fabric by sewing or
riveting. They would remain classified within subheading 9606.10, HTSUS, even if the

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separate parts are attached to strips of narrow tape or fabric. Both parts, however,
must be imported within the same shipment.

Subheadings 9606.21, 9606.22 and 9606.29 cover buttons of all sizes, shapes and
types. Buttons are often flat, with holes through them to enable one to attach them to a
garment or intended item. There are also buttons referred to as shank buttons. These
buttons have a raised part on the back of the button used for attaching it to its intended
item. Shank buttons may also have a spring-type hinge that will enable the button to be
secured to the garment by a means other than sewing. A “bachelor button” is another
form of a button that can be secured to a garment without sewing. These subheadings
do not include cuff-links.

Heading 9606 also covers button molds. A button mold is a button “blank.” They are
unfinished buttons that are clearly recognizable as such. Finishing touches that may
need to be added would be trimming, piercing or polishing. A disc that has been sawn,
cut or polished, but not further worked, such as shaped with rimmed edges, would not
be clearly identifiable as intended for making buttons and would be classified according
to the constituent material.

Buttons within subheading 9606.21 and 9606.29 have an unusual unit of quantity
reporting and duty rate calculation. The unit of quantity is gross and gross lines. The
duty rate is based upon ¢/line/gross + an ad valorem duty rate. One gross is equivalent
to 144 buttons. A 460,800 piece count of buttons would be equivalent to 3,200 gross.
A line (or ligne) is the basis of button measurement. Additional U.S. Note 1 to Chapter
96 states a “line” in the rates of duty columns is equivalent to 0.635 mm. In other
words, the line measures the size.

Line mm inches
1 0.635 0.025”
12 7.620 0.300”
20 12.700 0.500”
30 19.050 0.750”
40 25.400 1.000”

If you have a 10.160 mm diameter button, the line is 16 (10.160/0.635).

Example:

There’s an importation of 3200 gross buttons, size 17 lines. The proper classification is
9606.29.20. The duty rate is 0.3¢/line/gross + 4.5%.
Reporting unit of quantity is: 3200 gross; 54400 gross line (3200 gross x 17 lines)
Duty rate is calculated .003 x 17 x 3200 = $163.20 + 4.5% of the value.

Functional, as well as decorative buttons can be classified here, but not buttons
intended as articles of personal adornment. Also excluded from heading 9606 are
buttons where the precious metal is more than a minor component.

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Heading 9607

9607 Slide fasteners and parts thereof:
Slide fasteners:
9607.11.00 00 Fitted with chain scoops of base metal
9607.19.00 Other
20 Fitted with chain scoops of plastic
40 Fitted with continuous plastic filament
60 Other
9607.20.00 Parts
40 Sliders, with or without pulls
80 Other

DEFINITIONS

Slide Fastener
Fastening/binding device such as a zipper found on textile items or sliders found
on plastic sandwich bags. Interlocks two pieces together to form a single piece.
Chain Scoop
A scoop is another term for teeth. A chain scoop creates an interlocking
fastening function along the chain of scoops.
Plastic Filament
A plastic slide fastener, such as those found on plastic zipper seal bags. The two
strips of plastic have specially shaped edge designs enabling them to interlock
through a slider action.
Slider/Runner
The element that slides along the zipper (or plastic filament) creating the
interlocking/sealing action.
Slider Pull
The tab or element that connects to the slider, enabling an easier grasp and
movement of the slider along the chain or filament.

The above referenced definitions should assist to clarify the subheadings of heading
9607. Hook and loop fastener tape that consists of the hook (male) and the loop
(female) portions of the fastener tape, both narrow fabrics of woven pile construction,
are not classified within heading 9607. Although there is a certain fastening capability,
this is not considered a type of slide fastener. Parts of slide fasteners would include
chain scoops (teeth), sliders, end pieces (top stop or bottom stop), pull tabs and narrow
strips of tape, any length, if the scoops have been mounted to them.

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ADDITIONAL INFORMATION

The Internet

The home page of U.S. Customs and Border Protection on the Internet’s World Wide
Web, provides the trade community with current, relevant information regarding CBP
operations and items of special interest. The site posts information -- which includes
proposed regulations, news releases, publications and notices, etc. -- that can be
searched, read on-line, printed or downloaded to your personal computer. The web site
was established as a trade-friendly mechanism to assist the importing and exporting
community. The web site also links to the home pages of many other agencies whose
importing or exporting regulations that U.S. Customs and Border Protection helps to
enforce. The web site also contains a wealth of information of interest to a broader
public than the trade community. For instance, the “Know Before You Go” publication
and traveler awareness campaign is designed to help educate international travelers.

The web address of U.S. Customs and Border Protection is http://www.cbp.gov

Customs Regulations

The current edition of Customs and Border Protection Regulations of the United States
is a loose-leaf, subscription publication available from the Superintendent of
Documents, U.S. Government Printing Office, Washington, DC 20402; telephone (202)
512-1800. A bound edition of Title 19, Code of Federal Regulations is also available for
sale from the same address. All proposed and final regulations are published in the
Federal Register, which is published daily by the Office of the Federal Register, National
Archives and Records Administration, and distributed by the Superintendent of
Documents. Information about on-line access to the Federal Register may be obtained
by calling (202) 512-1530 between 7 a.m. and 5 p.m. Eastern time. These notices are
also published in the weekly Customs Bulletin described below.

Customs Bulletin

The Customs Bulletin and Decisions (“Customs Bulletin”) is a weekly publication that
contains decisions, rulings, regulatory proposals, notices and other information of
interest to the trade community. It also contains decisions issued by the U.S. Court of
International Trade, as well as customs-related decisions of the U.S. Court of Appeals
for the Federal Circuit. Each year, the Government Printing Office publishes bound
volumes of the Customs Bulletin. Subscriptions may be purchased from the
Superintendent of Documents at the address and phone number listed above.

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Importing into the United States

This publication provides an overview of the importing process and contains general
information about import requirements. The current edition of Importing Into the United
States contains much new and revised material brought about pursuant to the Customs
Modernization Act (“Mod Act”). The Mod Act has fundamentally altered the relationship
between importers and U.S. Customs and Border Protection by shifting to the importer
the legal responsibility for declaring the value, classification, and rate of duty applicable
to entered merchandise.

The current edition contains a section entitled "Informed Compliance." A key component
of informed compliance is the shared responsibility between U.S. Customs and Border
Protection and the import community, wherein CBP communicates its requirements to
the importer, and the importer, in turn, uses reasonable care to assure that CBP is
provided accurate and timely data pertaining to his or her importation.

Single copies may be obtained from local offices of U.S. Customs and Border
Protection, or from the Office of Public Affairs, U.S. Customs and Border Protection,
1300 Pennsylvania Avenue NW, Washington, DC 20229. An on-line version is
available at the CBP web site. Importing into the United States is also available for
sale, in single copies or bulk orders, from the Superintendent of Documents by calling
(202) 512-1800, or by mail from the Superintendent of Documents, U.S. Government
Printing Office, P.O. Box 979050, St. Louis, MO 63197-9000.

Informed Compliance Publications

U.S. Customs and Border Protection has prepared a number of Informed Compliance
publications in the “What Every Member of the Trade Community Should Know
About:...” series. Check the Internet web site http://www.cbp.gov for current
publications.

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Value Publications

Customs Valuation under the Trade Agreements Act of 1979 is a 96-page book
containing a detailed narrative description of the customs valuation system, the customs
valuation title of the Trade Agreements Act (§402 of the Tariff Act of 1930, as amended
by the Trade Agreements Act of 1979 (19 U.S.C. §1401a)), the Statement of
Administrative Action which was sent to the U.S. Congress in conjunction with the TAA,
regulations (19 C.F.R. §§152.000-152.108) implementing the valuation system (a few
sections of the regulations have been amended subsequent to the publication of the
book) and questions and answers concerning the valuation system.

Customs Valuation Encyclopedia (with updates) is comprised of relevant statutory
provisions, CBP Regulations implementing the statute, portions of the Customs
Valuation Code, judicial precedent, and administrative rulings involving application of
valuation law. A copy may be purchased for a nominal charge from the Superintendent
of Documents, Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-
7054. This publication is also available on the Internet web site of U.S. Customs and
Border Protection.

The information provided in this publication is for general information
purposes only. Recognizing that many complicated factors may be
involved in customs issues, an importer may wish to obtain a ruling under
CBP Regulations, 19 C.F.R. Part 177, or obtain advice from an expert
(such as a licensed Customs Broker, attorney or consultant) who
specializes in customs matters. Reliance solely on the general
information in this pamphlet may not be considered reasonable care.

Additional information may also be obtained from U.S. Customs and Border Protection
ports of entry. Please consult your telephone directory for an office near you. The
listing will be found under U.S. Government, Department of Homeland Security.

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“Your Comments are Important”

The Small Business and Regulatory Enforcement Ombudsman and 10 regional
Fairness Boards were established to receive comments from small businesses about
Federal agency enforcement activities and rate each agency’s responsiveness to small
business. If you wish to comment on the enforcement actions of U.S. Customs and
Border Protection, call 1-888-REG-FAIR (1-888-734-3247).

REPORT SMUGGLING 1-800-BE-ALERT OR 1-888-NO-DROGA

Visit our Internet web site: http://www.cbp.gov