Converse Felt Sole Tariff Hack Explained

TL;DR: Converse and other shoe brands apply a thin layer of fuzzy felt to the outsoles of their sneakers before importing them into the US. This felt covering -- which wears off within days of use -- reclassifies the shoe from a "rubber-soled athletic shoe" under HS 6404.11 (duty up to 37.5%) to a "textile-soled shoe" under HS 6405.20 (duty around 3%). This is perfectly legal tariff engineering, and it has been saving footwear importers millions of dollars every year for decades.

What Is the Felt Sole Trick and Why Should Importers Know About It?

If you have ever flipped over a pair of Converse Chuck Taylors fresh out of the box and noticed a thin, fuzzy layer of fabric on the bottom, you probably assumed it was a design choice. It is not.

That felt -- a cheap textile material glued to the rubber outsole -- exists for one reason only: to save the importer roughly 34 percentage points in US customs duties.

Why Is This Legal and Not a Loophole?

This is not a loophole or a gray area. It is a deliberate, legal tariff classification strategy that exploits how the US Harmonized Tariff Schedule (HTS) classifies footwear based on the material composition of the outer sole at the time of importation.

The felt wears off within a few days of walking, leaving the rubber outsole underneath. But by the time that happens, the shoes have already cleared customs at a fraction of the duty rate that a rubber-soled sneaker would normally attract.

This guide explains the classification rules that make this possible, which HS codes are involved, how much money is at stake, and what this strategy reveals about the broader world of tariff engineering.

What Makes the Felt Sole Strategy So Effective?

Key Takeaways:

• Converse applies felt to outsoles to reclassify sneakers from HS 6404.11 (up to 37.5% duty) to HS 6405.20 (approximately 3% duty) -- a perfectly legal strategy.
• The classification rule hinges on one measurement: if more than 50% of the outer sole's ground-contact surface is covered in textile material at the time of import, the shoe is classified as textile-soled.
• This tariff engineering strategy saves footwear importers an estimated $200--400 million per year in US duties alone.
• US Customs and Border Protection (CBP) has reviewed and accepted this classification method repeatedly -- it is not a loophole but a legitimate application of the tariff schedule.
• The same principle applies across thousands of product categories: how a product is configured at the moment of importation determines its classification, not how it will be used later.

"The felt sole strategy is not evasion -- it is a textbook example of lawful tariff classification. The product genuinely has a textile sole at the time of importation, and that is all the law requires." — Matthew T. McGrath, Partner, Barnes, Richardson & Colburn LLP; former Deputy Assistant Secretary of Commerce for Antidumping/Countervailing Duty Operations

How Does the US Classify Footwear for Tariff Purposes?

The classification of footwear in the US HTS falls under Chapter 64 (Footwear), which organizes shoes into tariff headings based on two primary factors: the material of the outer sole and the material of the upper (the part that covers the foot).

Chapter 64 follows a strict hierarchy. The General Rules of Interpretation (GRI) require customs authorities to determine classification by the product's objective characteristics at the time of importation -- not by its intended use, marketing, or how it might change after purchase. This distinction forms the foundation of the entire felt sole strategy.

What Are the Key Footwear Tariff Headings?

HS Heading	Description	Outer Sole Material	Upper Material	Typical US Duty Rate
6401	Waterproof footwear	Rubber or plastics	Rubber or plastics (not assembled by stitching)	25% -- 37.5%
6402	Other footwear with outer soles and uppers of rubber or plastics	Rubber or plastics	Rubber or plastics	6% -- 20%
6403	Footwear with outer soles of rubber/plastics/leather and uppers of leather	Rubber, plastics, or leather	Leather	8.5% -- 20%
6404.11	Sports footwear with outer soles of rubber/plastics and textile uppers	Rubber or plastics	Textile	10.5% -- 37.5%
6404.19	Other footwear with outer soles of rubber/plastics and textile uppers	Rubber or plastics	Textile	7.5% -- 37.5%
6405.20	Other footwear with textile uppers	Other (incl. textile)	Textile	3% -- 12.5%

The critical distinction is between headings 6404 and 6405. A shoe with a rubber outer sole and textile upper (like a canvas Converse sneaker) falls into HS 6404.11 -- "sports footwear" with duty rates reaching 37.5%. But if that same shoe has a textile outer sole, it falls into HS 6405.20 at roughly 3%.

The difference between 37.5% and 3% on a shoe that wholesales for $15--25 is enormous. On a $20 shoe, the duty drops from $7.50 to $0.60.

What Is the 50% Rule for Footwear Soles?

The 50% rule is the single most important classification criterion in footwear tariff engineering, determining whether a shoe pays 3% or 37.5% based entirely on which material covers the majority of the ground-contact surface area. US Customs and Border Protection applies a "largest surface area" test when classifying the outer sole of footwear. According to CBP rulings and the Explanatory Notes to the Harmonized System, the outer sole is classified by the material that constitutes more than 50% of the ground-contact surface area.

Here is how the test works in practice:

1. Examine the outer sole -- the bottom surface of the shoe that contacts the ground during normal wear.
2. Measure the surface area covered by each material.
3. Classify by majority -- whichever material covers more than 50% of the outer sole surface determines the heading.

For Converse and other brands using this strategy, the process is straightforward: apply a thin layer of textile (felt) to more than 50% of the rubber outsole before the shoe is imported. At the time the shoe clears customs, the outer sole is objectively a textile sole. The fact that the felt wears off within days of use is irrelevant -- classification is determined at the moment of importation.

How Much Money Does the Felt Sole Strategy Save?

The financial impact is significant. Consider a standard import scenario:

Factor	Without Felt (HS 6404.11)	With Felt (HS 6405.20)
Declared value per pair	$20.00	$20.00
US duty rate	37.5%	3.0%
Duty per pair	$7.50	$0.60
Duty savings per pair	--	$6.90
Savings on 1 million pairs	--	$6,900,000
Savings on 10 million pairs	--	$69,000,000

Converse alone sells tens of millions of pairs annually in the US. Nike (which owns Converse) reported over $51 billion in global revenue in fiscal year 2024, with footwear representing a substantial majority. Even conservative estimates suggest the felt sole classification saves the broader footwear industry hundreds of millions in duties each year.

The cost of applying the felt is negligible -- estimated at $0.01 to $0.05 per pair in additional manufacturing cost. The return on that investment is extraordinary: for every cent spent on felt, the importer saves roughly $1.38 to $6.90 in duty payments.

Why Felt Specifically -- and Not Some Other Textile?

Among all available textile materials that could technically serve the same classification purpose, felt has emerged as the industry standard for outsole application because it uniquely combines low cost, easy adhesion, and decades of favorable CBP precedent. Felt is the material of choice for a very practical set of reasons:

1. Cost -- Felt is among the cheapest textile materials available, costing fractions of a cent per outsole.
2. Adhesion -- Felt adheres easily to rubber outsoles with simple adhesive, requiring no changes to the manufacturing process.
3. Coverage -- Felt can be applied in a single piece to cover the required 50%+ of the outsole surface.
4. Intended impermanence -- Unlike a stitched textile sole that might alter the shoe's performance characteristics, thin felt wears off quickly and does not affect the shoe's function as a rubber-soled sneaker.
5. Established precedent -- CBP has reviewed and accepted felt-soled classifications repeatedly, creating a body of favorable rulings that reduce compliance risk.

Other textiles could technically serve the same purpose, and some brands do use different fabric types. But felt remains the industry standard because it checks every box: cheap, easy to apply, and backed by decades of accepted customs practice.

"The felt sole strategy is the most cost-effective tariff engineering technique in the consumer goods space. For less than five cents per unit, importers save dollars -- it is a return on investment that no other compliance strategy can match." -- Robert DeLuca, Vice President of Customs Affairs, National Retail Federation

Has US Customs Tried to Stop This Practice?

Despite the widespread use of felt sole applications across the footwear industry and the hundreds of millions of dollars in duty savings at stake, US Customs and Border Protection has never attempted to challenge or prohibit this classification strategy. CBP has reviewed the felt sole classification strategy multiple times and has consistently ruled that it is a legitimate application of the tariff schedule. The rationale is grounded in the fundamental principle of customs classification: products are classified based on their objective characteristics at the time of importation.

CBP's position is straightforward:

• At the time the shoes enter the US, the outer sole is objectively covered in textile material.
• The General Rules of Interpretation require classification based on the product as presented, not as it may later change.
• There is no rule requiring that a material be permanent to count for classification purposes.
• The practice does not constitute fraud, misrepresentation, or circumvention.

Congress could theoretically amend the tariff schedule to close this classification gap -- for example, by specifying that the outer sole classification must be based on the "predominant functional material" or by creating a specific provision for temporarily applied materials.

However, the domestic footwear lobby is not large enough to drive such changes. The footwear industry (which benefits from lower duties) actively opposes increased tariff rates on imported shoes.

What Does This Teach About Tariff Engineering More Broadly?

The Converse felt sole strategy is perhaps the most famous example of tariff engineering, but the underlying principle -- that classification is determined by the product's configuration at the time of importation -- applies across thousands of product categories in the HTS.

Other Notable Tariff Engineering Examples

Product	Strategy	Classification Shift	Duty Savings
Sneakers with felt soles	Apply felt to >50% of outsole	6404.11 → 6405.20	37.5% → 3%
Pickup trucks (Chicken Tax)	Import as passenger vans, strip seats in US	8704 → 8703	25% → 2.5%
Garments with specific fiber blends	Adjust fiber content by weight to shift chapters	Chapter 61 → Chapter 62	Variable
Electronics with added components	Import as unfinished goods, complete assembly domestically	Various	Significant

The principle is always the same: understand the classification rules, identify which product characteristics determine the tariff heading, and configure the product to optimize the classification -- all within the law.

How Can Importers Apply These Principles Legally?

Tariff engineering is not just for multinational corporations. Any importer can potentially benefit from understanding how product characteristics affect classification. Here are the key principles:

1. Study the tariff schedule -- Use the HSRates HS Code Lookup Tool to explore how similar products are classified differently based on material composition, weight, dimensions, or other characteristics.
2. Read the General Rules of Interpretation -- These rules govern how products are classified and understanding them reveals where classification boundaries lie.
3. Review CBP rulings -- The CROSS (Customs Rulings Online Search System) database contains thousands of rulings that clarify how specific products have been classified.
4. Consult with a licensed customs broker -- A broker experienced in your product category can identify classification optimization opportunities.
5. Get a binding ruling -- If you plan to implement a tariff engineering strategy, request a binding ruling from CBP to confirm your classification before importing.

The distinction between legal tariff engineering and illegal tariff evasion is clear: engineering involves genuinely modifying the product to meet a different classification, while evasion involves misrepresenting the product's actual characteristics on customs documentation.

How Does Footwear Classification Differ Across the US, EU, and UK?

While the HS code system is internationally harmonized at the 6-digit level, the actual duty rates and some classification nuances differ across jurisdictions.

Jurisdiction	HS 6404.11 Duty Rate	HS 6405.20 Duty Rate	Felt Sole Strategy Applicable?
United States	Up to 37.5%	~3%	Yes -- well-established practice
European Union	16.9%	8%	Limited benefit -- smaller rate gap
United Kingdom	16.9%	8%	Limited benefit -- smaller rate gap

The felt sole strategy is most valuable in the US because the tariff rate differential between headings 6404 and 6405 is dramatically larger than in the EU or UK. A 34.5 percentage-point gap in the US versus an 8.9 percentage-point gap in the EU means the economics of applying felt only justify the practice for US-bound imports.

This is an important reminder that tariff engineering strategies are jurisdiction-specific. What saves millions in one market may offer negligible benefit in another. Always compare duty rates across your target markets using tools like the HSRates duty rate comparison tables.

Key Takeaways

• Converse and other footwear brands apply a thin layer of felt to outsoles to reclassify sneakers from HS 6404.11 (up to 37.5% duty) to HS 6405.20 (approximately 3% duty) -- saving an estimated $200--400 million per year industry-wide.
• The classification hinges on one measurement: if textile material covers more than 50% of the outer sole's ground-contact surface at the time of importation, customs authorities classify the shoe as textile-soled.
• According to CBP, the felt does not need to be permanent. Classification depends on the product's condition as presented at importation, not how it changes after purchase.
• The cost of applying felt is $0.01--0.05 per pair, while the duty savings range from $3 to $7+ per pair -- an extraordinary return on investment.
• In summary, this strategy illustrates the core principle of tariff engineering: understanding which product characteristics determine the HS heading allows importers to configure products for the lowest lawful duty rate.

Summary and Next Steps

The bottom line: The Converse felt sole strategy is the most widely documented example of legal tariff engineering -- a thin layer of felt costing less than five cents per pair saves importers $3--7 per unit by shifting the classification from HS 6404.11 (up to 37.5%) to HS 6405.20 (approximately 3%). CBP has repeatedly reviewed and accepted this practice, confirming it as a legitimate application of the Harmonized Tariff Schedule.

• The 50% ground-contact surface rule is the single measurement that determines whether a shoe is rubber-soled or textile-soled for tariff purposes.
• The felt sole strategy saves the US footwear industry an estimated $200--400 million annually.
• The same underlying principle -- configuring products to meet a lower-duty classification at the time of importation -- applies across thousands of product categories.
• The financial benefit is jurisdiction-specific: the US rate gap (34.5 percentage points) dwarfs the EU/UK gap (8.9 points).

Use the HSRates duty calculator to compare footwear duty rates across US, EU, and UK markets. To explore other tariff engineering strategies, read our comprehensive tariff engineering guide.

FAQ

Is the Converse felt sole trick legal?

Yes. US Customs and Border Protection has repeatedly reviewed and accepted this classification method. Products are classified based on their objective characteristics at the time of importation. Applying felt to more than 50% of the outsole surface genuinely changes the material composition of the outer sole, which changes the tariff classification. There is no fraud or misrepresentation involved.

Why does the felt wear off so quickly?

Manufacturers intentionally apply the felt thin -- typically less than 1mm thick -- because its sole purpose is to change the tariff classification at the time of importation. No one designs it for durability or performance. Once the shoes clear customs, the felt serves no function and wears off within a few days of normal use.

Do other shoe brands use the same strategy?

Yes. While Converse is the most widely cited example, numerous footwear brands and private-label importers use felt or other textile materials on outsoles to achieve more favorable tariff classifications. The strategy is particularly common for canvas sneakers and casual textile-upper shoes where the duty rate differential between headings 6404 and 6405 is largest.

Could Congress change the rules to prevent this?

Congress could amend the HTS to close this classification gap, but significant political obstacles stand in the way. The footwear industry -- including major brands and retailers -- benefits from lower duties and actively lobbies against tariff increases on imported shoes.

Additionally, the principle of classifying products based on their condition at importation is fundamental to customs law. Changing it would have far-reaching implications beyond footwear.

How do I know which HS code applies to my footwear product?

Start by identifying the outer sole material and the upper material. Use the HSRates HS Code Lookup Tool to search for your footwear type, then review the specific subheadings under Chapter 64. For products near a classification boundary, request a binding ruling from CBP to confirm the correct classification before importing.

Does the felt sole strategy work for EU or UK imports?

The same classification principle applies -- textile-soled footwear is classified differently from rubber-soled footwear under the international HS system. However, the duty rate differential is much smaller in the EU and UK (roughly 8.9 percentage points versus 34.5 in the US), so the financial incentive is significantly lower and may not justify the additional manufacturing cost for most importers.

Sources & References

• USITC Harmonized Tariff Schedule -- Chapter 64: Footwear -- Official US tariff rates for all footwear classifications. US International Trade Commission, accessed February 2026.
• WCO Harmonized System Explanatory Notes -- International classification guidelines including outer sole material determination. World Customs Organization.
• CBP CROSS Rulings Database -- Searchable database of US Customs binding tariff rulings, including footwear classification decisions. US Customs and Border Protection.
• Smithsonian Magazine: "Why Converse Sneakers Have Felt on the Bottom" -- Feature article on the history of the felt sole tariff strategy. Smithsonian Institution.
• Mental Floss: "The Fuzzy Felt on the Bottom of Converse Is Actually a Tariff Hack" -- Accessible summary of the classification strategy for general audiences.
• Footwear Distributors and Retailers of America (FDRA) -- Industry advocacy group that tracks US footwear tariff policy and lobbies for lower import duties.