WORLD TRADE
ORGANIZATIONG/RO/45/Add.2/Rev.1
20 September 2001
(01-4479)
Committee on Rules of Origin
INTEGRATED NEGOTIATING TEXT FOR THE
HARMONIZATION WORK PROGRAMME
CHAPTERS 64-67 (FOOTWEAR AND HEADGEAR)
Note by the Secretariat
Revision
1. At its meeting on 10 May 1996, the Committee on Rules of Origin (CRO) decided to establish
an Integrated Negotiating Text (INT) for the Harmonization Work Programme.  The first INT was
circulated in document G/RO/W/13 (24 May 1996), and had been periodically updated
(G/RO/W/13/Rev.1-3, G/RO/W/13/Rev .3/Add.1 and 2).  A further consolidated INT was circulated in
document G/RO/41(3 September 1999), and has also  been periodically updated (JOB(99)/5869, JOB
(99)/7617, JOB(00)/1573, JOB(00)/3230, JOB(00) /5207 and JOB(00)/7194).
2. The attached document is the latest update of the negotiating text of chapters 64-67 (footwear
and headgear) and reflects the progress made by the CRO  in July 2001.G/RO/45/Ad d.2/Rev.1
Page 2
ISSUES FOR DECISION; CHAPTERS 64-67
ISSUE FOR DECISION NO. 1
1. "Blocking" as a necessary manufacturing process in conferring origin on products of
heading 65.03 made from products of other heading.
Differing views presented in the relevant Technical Committee discussions
OPTION A
2. Felt hats and other felt headgear of heading 65.03 are made from semi-manufactured
products, namely, felt hat forms, felt hat bodies, etc. classified in heading 65.01.  There is a marked
difference between the input products and the resulting products.  A "CTH" is therefore an adequate
expression of substantial transformation for the products of heading 65.03 made from products of
heading 65.01. (JPN) ( CH) (EC)  (MEX) (MAL) (CAN) ( PHI)
OPTION B
3. Felt hat forms and similar articles of heading 65.01 can change classification to heading 65.03
by simple addition of brims or other accessory parts without blocking.  This addition does not
constitute a substantial transformation.  The “CTH” is therefore not an adequate formulation toexpress the substantial transformation of the products of heading 65.03 made from products of
heading 65.01.
4. In the manufacture of felt hats or other felt headgear from products of heading 65.01,
blocking is an important process. This produces th e final shape and fixes the size of the end products.
5. To express substantial transformation of the products of heading 65.03 from products of
heading 65.01 through blocking, the origin rule should be formulated as "CTH, provided a blocking
process has occurred". (IND) (KOR) (US) (AUS) (BRA) (EGY)
Relevant HS code number
6. Heading 65.03: felt hats and other felt headgear, made from the hat bodies, hoods or plateaux
of heading No. 65.01, whether or not lined or trimmed.
Reference
7. Doc. 40.245 (Annexes E/1 and E/2)
Doc. 40.840 (Annexes E/1 and E/2)
Doc. 41.490
ISSUE FOR DECISION NO. 28.           "locking to shape and further finishing
" as necessary manufacturing processes in conferring
origin on products of heading 65.04 made from products of other heading.G/RO/45/Ad d.2/Rev.1
Page 3
Differing views presented in the relevant Technical Committee discussion
OPTION A
9.           Hats and other headgear of heading 65.04 are made from semi-manufactured products,
namely hat shapes of heading 65.02. There is a marked difference between the input products and the
resulting hats or headgear.  The formulation of “CTH” is therefore an adequate expression of
substantial transformation for hats or headgear  manufactured from hat shapes. (JPN) (CH) (EC)
(MEX) (MAL) (CAN) (PHI)
OPTION B
10          Hat shapes of heading 65.02 can change to products of heading 65.04 simply by addition of
brims or other accessory parts.  This does not bring about a substantial transformation.  The “CTH”
formulation is therefore not a sufficient expression for the substantial transformation of the products
of heading 65.04.
11.         In the manufacture of hats or headgear from plaited or otherwise produced hat shape s of any
material, blocking is an important process.  It produces permanently the shape and size of the hats or
headgear.  Other finishing operation (e.g. fitting with head-bands, linings, chinstraps, decorative
accessories, etc.) is also necessary to enhance the use as well as the appeal of the products.
12.         To express substantial transformation of the products of heading 65.04, the origin rule
formulation should be based on: "CTH, provided a blocking to shape and further finishing has
occurred". (IND) (US) (KOR) (EGY) (AUS) (BRA)
Relevant HS code number
13.         Heading 65.04: hats and other headgear, plaited or made by assembling strips of any material,
whether or not lined or trimmed.
Reference
14.         Doc. 40.245 (Annexes E/1 and E/2)
Doc. 40.840 (Annexes E/1 and E/2)
Doc. 41.490
ISSUE FOR DECISION NO. 3
15. Production of products of heading 65.05 by assembly of parts of other heading.
Differing views presented in the relevant Technical Committee discussion
OPTION A
16. Most component parts for hats and headgear (e.g. head-bands, linings, hat frames, peaks,
chinstraps, etc.) are classified in heading 65.07.  Some may come from other headings.  Assembly of
parts to form products of this heading is considered origin-conferring.  The origin rule formulation of
"CTH" therefore expresses adequately the substantial transformation of the products of heading 65.05made from parts of other headings. (IND)  (JPN) (CH) (EC) (CAN) (MEX) (PHI)G/RO/45/Ad d.2/Rev.1
Page 4
OPTION B
17. The assembly of parts to form hats and headgear of heading 65.05 may entail a substantial
transformation.  However, a condition has to be set that the assembling operation must be fully carried
out in a single country.  The origin rule formulation for goods of heading 65.05 should be based on:"CTH, provided the goods are fully assemble d in a single country". (KOR) (US) (EGY)
Relevant HS code number
18. Heading 65.05: hats and other headgear, knitted or crocheted, or made up from lace, felt or
other textile fabric, in the piece (but not in strips), whether or not lined or trimmed; hair-nets of any
material, whether or not lined or trimmed.
Reference
19. Doc. 40.245 (Annexes E/1 and E/2)
Doc. 40.840 (Annexes E/1 and E/2)Doc. 41.490
ISSUE FOR DECISION NO. 420.         Production of umbrellas of heading 66.01 by as
sembly of parts of other heading.
Differing views presented in the relevant Technical Committee discussion
OPTION A
21.         The umbrellas and sun umbrellas re ferred to in heading 66.01 may be manufactured from
textile fabric, plastics, paper, etc. of other headings and/or from parts of heading 66.03.  A change to
the heading of the finished products from that of the input products is therefore an adequate
expression of the substantial transformation of the goods.  The origin rule formulation of  “CTH” is
considered appropriate for products of head ing 66.01. (CH) (CAN) (IND) (JPN) (MAL) (MEX)
(KOR) (PHI)
OPTION B
22.         Heading 66.03 covers handles and knobs, umbrella frames and other parts, trimmings and
accessories of articles of heading 66.01 or 66.02.  Manufacture of umbrellas of heading 66.01 from
these parts, trimmings and accessories does not bring about a substantial transformation.  Substantial
transformation is deemed to have occurred when the umbrellas are manufactured from such materials
as textile fabric, plastics, paper, etc. classified in other headings except heading 66.03.  The origin rule
formulation for the goods of heading 66.01 should read: “CTH, except from heading 66.03”. (EC)
OPTION C
23.         The production of umbrellas of heading 66.01 by a ssembly of parts of umbrellas, trimmings
and accessories of any other headings (including heading 66.03) is considered to be origin-conferring
subject to the condition that the assembling operation must be fully carried out in a single country.
The origin rule formulation for goods of headin g 66.01 should be based on: “CTH, provided that the
goods are fully assembled in a single country”.(US, EGY)G/RO/45/Ad d.2/Rev.1
Page 5
Relevant HS code number
24.         Heading 66.01: Umbrellas, sun um brellas (including walking-stick umbrellas, ga rden
umbrellas and similar umbrellas).
Heading 66.03: parts, trimmings and accessories of articles of heading No. 66.01 or 66.02
Reference
25.         Doc. 40.245 (Annexes E/1 and E/2)
Doc. 40.840 (Annexes E/1 and E/2)
Doc. 41.490
ISSUE FOR DECISION NO. 5
26. Production of products of heading 66.02 by assembly of parts from other heading.
Differing views presented in the relevant Technical Committee discussion
OPTION A
27.         The products of heading 66.02 may be manufactured from parts of heading 66.03 and /or from
materials of any other heading.  A change to the heading of the finished products from that of the
input products is therefore sufficient for expressing substantial transformation of the goods.  The
origin rule formulation of “CTH” is appropriate for products of heading 66.02. (IND) (JPN) (MEX)
(MAL) (KOR) (EGY) (US) (CAN) ( PHI)
OPTION B
28.         The production of walking-sticks, whip s, riding-crops, etc. of heading 66.02 by assembly of
parts of umbrellas, trimmings and accessories from any other headings (including heading 66.03) is
not considered to be origin-conferring.  The origin rule formulation for products of heading 66.02
should read: “CTH, except from heading 66.03’.(EC)
Relevant HS code number
29.         Heading 66.02: walking-sticks, seat-stick s, whips, riding-crops and the like.
Heading 66.03: parts, trimmings and accessories of articles of heading No. 66.01 or 66.02
Reference
30.         Doc. 40.245 (Annexes E/1 and E/2)
Doc. 41.490
ISSUE FOR DECISION NO. 6
31.         A change to the products of headin g 67.01 from those of heading 05.05; and removal of
feathers, parts of feathers, or down of heading 67.01 from the skins and other parts of birds with their
feathers or down of the same heading.
For ex 67.01(c), there is a consensus on CTHS.G/RO/45/Ad d.2/Rev.1
Page 6
Differing views presented in the relevant Technical Committee discussion
OPTION A
32.         Heading 67.01 covers the following products:
Skins and other parts of birds with their feathers or down
Feathers, parts of feathers, and down
Articles made from the above products
33.         The input products for the production of skins and other parts of birds with their feathers or
down of heading 67.01 are classified in other heading.  Hence, the origin rule formulation of “CTH” is
considered appropriate for the products.
34.         The  change to feathers, parts of feathers, and down of the heading from skins and other parts
of birds with their feathers or down of the same heading is a substantial transformation.  It involves a
significant modification of the input products.  In industry, removal of feathers or down from skins is
complicated and required specialized techniques in plucking, separation and other follow-up
treatments.  A split heading rule for the resulting products is considered necessary.
35.         The manufacture of articles o f feathers or down from feathers, parts of feathers, or down
entails a substantial transformation of the input products.  A split heading rule is also considered
necessary for the articles so produced.
36.         To sum up, the origin rules for products of hea ding 67.01 should be:
ex 67.01 (a) CTH           (IND)  (JPN) (MEX) (CH) (CAN) (MAL) (KOR).
ex 67.01 (b) CTHS         (US) ( IND) (J PN) (MEX) (CH) (CAN) (M AL) (KOR) (NOR) (PHI) 
(EGY).
OPTION B
37.         Heading 05.05 refers to unworked feathers, down, etc. that have been cleaned, disinfected or
treated for preservation.  A change from these products to products of  heading 67.01 does not stand
for any significant transformation.  The input materials for products of heading 67.01 should  be
traced back to any other heading but not to head ing 05.05.  Accordingly, the origin rule formulation
for heading 67.01 should read: “CTH, except from heading 05.05”.
38.         Also, the change to feathers, parts of feathers or down of heading 67.01 from skins and other
parts of birds with their feathers or down of the same heading cannot be treated as a substantial
transformation.
39.         It is acknowledged, however, that a change to articles from feathers, down, skins with
feathers or down, etc. of headings 67.01 and 05.05 constitutes a substantial transformation.
40.         The origin rules should be :
ex 67.01(a) – CTH, except from 0505 (EC) (NOR) (EGY) (PHI).
ex 67.01(b) – CTH, except from 0505 (EC).
Relevant HS Code number
41.         Heading 67.01: skins and other parts of birds with their feathers or dow n, feathers, parts of
feathers, down and articles thereof (other than goods of heading No. 05.05 and worked quills and
scapes)G/RO/45/Ad d.2/Rev.1
Page 7
Heading 05.05: skins and other parts of birds, with  their feathers or down, feathers and parts
of feathers (whether or not with trimmed ed ges) and down, not further worked than cleaned,
disinfected or treated for preservation; powder and waste of feathers or parts of feathers.
Reference
42.         Doc. 40.245 (Annexes E/1 and E/2)
Doc. 41.490
ISSUE FOR DECISION NO. 7
43. Assembly of parts to form artificial flowers.  Also, the assembly of artificial flowers, foliage
or fruit to form articles of artificial flowers, foliage or fruit.
Differing views presented in the relevant Technical Committee discussion
OPTION A
44. Artificial flowers, foliage and fruit of heading 67.02 may be obtained by assembling of parts
(e.g. leaves, stems, stamens, ovaries and petals) classified in the same heading or produced by
moulding or otherwise from materials classified in other headings.  These artificial flowers, foliage,
fruit and parts thereof may be further assembled into articles (e.g. bouquets, garlands, wreaths, plants)or other articles for use as trimmings or as ornaments.
45. Assembly of parts to goods gives the resulting products the essential likeness of the finished
flowers, foliage or fruit distinct from the input products.  Accordingly, the following formulations
should be considered : (IND, PHI, MOR, KOR)
ex 67.02 (a) Artificial flowers, foliage and fruit CTH, or CTHS from
ex 67.02 (b)
ex 67.02 (b) Parts CTHex 67.02 (c) Articles made of artificial flowers, CTHS
foliage or fruit
OPTION B
46. Materials used in the manufactured of parts of artificial flowers and fruits are classified
outside heading 67.02.  A change to products of heading 67.02 from any other heading constitutes
substantial transformation and confers origin.  The origin rule formulation of “CTH” is considered
appropriate for the products. (EC) (MAL) (JPN) (MEX) (EGY)
Relevant HS code number
47. Heading 67.02: artificial flowers, foliage and fruit and parts thereof; articles made of artificial
flowers, foliage or fruit.
Reference
48. Doc. 40.245 (Annexes E/1 and E/2)
Doc. 41.490G/RO/45/Ad d.2/Rev.1
Page 8
ISSUE FOR DECISION NO. 8
49. Production of products of heading 67.03 from materials of other heading.Differing views presented in the relevant Technical Committee discussion
OPTION A
50.         Heading 67.03 covers human hair which has been dressed or otherwise worked (for example,
thinned, bleached, dyed, waved or curled) for use in postiche or for other purposes.  It also covers
wool or other animal hair or other textile materials, prepared for use in making wigs or the like or
doll’s hair.  The input materials can be traced back to other headings, for example, heading 05.01
which covers the human hair that has not yet been dressed, thinned, bleached or dyed.  It is considered
that a change to products of this heading from the input materials is sufficient to confer origin.
Accordingly, “CTH” is an appropriate origin rule formulation for heading 67.03.
OPTION B
51.         The origin rule for products of heading 67.03 should be formulated as follows:
ex 67.03 (a) Human hair, dressed, thinned,
bleached or otherwise worked;
wool or other animal      
              hair prepared f or use in
making wigs or the likeCTH, except from
headings 05.01, 51.01
or 51.02
ex 67.03 (b) Other textile materials, prepared
for use in making wigs or the likeCTH, except from
headings of Chapters
54 and 55
52.         In respect of the first “ex out”, the  products (human hair dressed, thinned, etc.; wool and
animal hair prepared) under examination are not considered origin-conferring when they are made
from the following input materials:
Heading 05.01   Human hair, unworked, whether or not washed or scoured
   Heading 51.01   Wool, not carded or combed
Heading 51.02   Fine or coarse animal hair, not carded or combed
53.         In respect of the second “ex out”, a change to the textile materials concerned from man-made
filaments and man-made staple fibres as follo ws should not be treated as substantial transformation.
The preparation of textiles for use in making wigs or the like must be made from originating fibres.
Chapter 54         Man-made filaments
Chapter 55         Man-made staple fibres
Relevant HS code number
54.         H eading 67.03: human hair, dressed, thinned, bleached or otherwise worked; wool or other
animal hair or other textile materials, prepared for use in making wigs or the like.G/RO/45/Ad d.2/Rev.1
Page 9
Reference
55.         Doc. 40.245 (Annexes E/1 and E/2)
Doc. 40.840 (Annexes E/1 and E/2)
Doc. 41.490
ISSUE NO. 9: OBTAINING PRODUCTS OF SUBHEADING 6406.10 (UPPERS AND PARTS
THEREOF, OTHER THAN STIFFENERS)
OPTION A: Yes56. The production of uppers and parts thereof, other than stiffeners, from materials (leather,
textiles, etc.) classified in other headings involves sufficient processing operation to render the
resultant products different from the input materials.  Hence, a substantial transformation is deemed to
have occurred.  The origin rule for the product s is "CTH". (CH) (EC) (EGY) (IND) (JPN) (MOR)
(NOR) (HK) (PHI) (AUS) (BRA) (THA)
OPTION B: Yes, provided
57. This Option does not differ from Option A, in that the obtaining of products of this
subheading from materials (leather, textiles, etc.) classified in other Chapter is deemed to be a
substantial transformation.  However the "CTH" rule as preferred in Option A might give rise to themisinterpretation that obtaining parts from shoes by  disassembly is also a substantial transformation.
The origin rule suggested is "Change of Chapter (CC)". (MEX)
OPTION C: Yes, provided
58. The products under subheading 6406.10 could be grouped into (a) formed uppers, (b) uppers
other than formed uppers, and (c) parts of uppers.
For (a), the origin rule is CTSHS.  "Forme d uppers", according to the proponent, mean uppers
of heading 64.06 having closed bottoms, which have been shaped by lasting, moulding or otherwise,
but not by simply closing at the bottom.  (US) (CAN)
For (b), the obtaining of the products from materials classified in any other heading or within
subheading 6406.10 is origin-conferring or the products are either knitted to shape or fully assembled
in one country.  (US) (CAN)
For (c), the production of parts of uppers from products classified in other headings is deemed
to be a substantial transformation.  A "CTH" origin rule is preferred.  (US)
OPTION D: Yes, provided59. Same as in Option C, the products under subheading 6406.10 could be grouped into (a)
formed uppers, (b) uppers other than formed uppers, and (c) parts of uppers.
For (a), "lasting" is considered to be the essential operation in the production of "formed
uppers".  The country where the "lasting" operation was performed is the country of origin of the
formed uppers so produced.  (KOR)
For (b), the country of origin is the country where at least two of the following operations
were performed: (i) making fabric, leather, etc. (ii) cutting, (iii) assembling parts; or if no country
meets the above criteria, the country where assembly of parts was performed.  (KOR)G/RO/45/Ad d.2/Rev.1
Page 10
For (c), a change from products of any other heading is deemed to be a substantial
transformation.  The origin rule is "CTH".  (KOR)
Relevant HS Codes: 6406.10
ISSUE NO. 10: OBTAINING PRODUCTS OF SUBHEADING 6406.99
OPTION A:       Yes
60.         Subhea ding 6406.99 covers component parts of footwear not specified in subheadings
6406.10 to 6406.91.  It also covers gaiters, leggings and similar articles.
61.         The production of products of this subh eading from products (i.e., leather, textiles, plastics) of
other headings is deemed to have undergone sufficient processing to attain a substantial
transformation.  The origin rule proposed is CT H.  (CH) (EC) (EGY) (IND) (KOR) (MOR) (NOR)
(PHI) (AUS) (BRA) (HK) (THA) (JPN)
OPTION B:       Yes, provided
62.         The pro duction of products of this subheading from products of any other heading outside the
Chapter is deemed to be a substantial transformation.  The origin rule proposed is "Change of
Chapter (CC)". (MEX)
63.         The "CTH" rule as preferred in Option A above is not considered appropriate because it might
lead to the misinterpretation that origin could be conferred on parts obtained, by disassembly, from
finished footwear classified in other headings of Chapter 64.
OPTION C:       Yes, provided
64.         For "gaiters, le ggings and similar articles" of subheading 6406.99,  the origin rule proposed is
"CTSH, provided the goods are either knitted to shape or fully assembled in one country". This is
because substantial transformation of the goods is considered to be mainly the result of operations of
knitting parts to shape or assembly of all input parts into a complete product.  (US) (CAN)
65.         For "other parts of footwear" under the same subheading, a change to these products from the
input products classified in any other heading is deemed to be a substantial transformation.  Hence,
the origin rule proposed is "CTH".  (US) (CAN)
Relevant HS Codes :       
ex 6406.99 (a), ex 6406.99 (b)
ISSUE No. 11 :  SHOULD A DEFINITION OF “FORMED UPPERS” BE DRAFTED FOR THE
PURPOSES OF HEADINGS 64.01 TO 64.05?
OPTION A : Yes
66. For origin purposes, it is necessary to distinguish ordinary uppers from uppers with closed
bottoms and shaped by lasting, moulding or other pr ocessing.  the assembly of footwear from ordinary
uppers is considered origin-conferring; whereas the assembly of footwear from other types of uppersis not.  “formed uppers” is a convenient term to describe those uppers which do not entail a substantial
transformation when further worked into footwear.
67. The definition of “formed uppers” should be drafted as:G/RO/45/Ad d.2/Rev.1
Page 11
Uppers of Heading No. 64.06 having closed bottoms, which have been shaped by lasting,
moulding or otherwise, but not by simply cl osing at the bottom. (US) (HK) (CH) (MEX)
(CAN) (PHI)
OPTION B : Yes68. The definition of “formed uppers” should be drafted as:
Uppers with insole material attached to the upper, which would prevent the base of a foot
placed in the upper from coming contact with the ground.  Except for footwear of moccasin
style construction, where the upper material is continued under the foot to form an insole
from one continuous piece of leather. (AUS)
OPTION C : No69. “Formed uppers” is not a term found in the hs nomenclature nor in the corresponding
explanatory notes.  if the term “formed uppers” is to be used, efforts must first be made to define andagree on the meaning of “moulding”, ‘lasting”, and “closing” in the context of footwear production.
this is conceivably a difficult task.
70. The technical committee should forgo drafting the origin rules for footwear with reference to
the term “formed uppers”.  instead, a more neutral and user-friendly terminology should be found.  inthis connection, the origin rule for footwear of headings  64.01 to 64.05 could be drafted as follows:
• CTH with the exclusion of assembly of uppers affixed to inner or to other sole components of
heading 64.06. (EC) (JPN) (IND)
Relevant HS Codes
Chapter Note 1
 
 ISSUE No. 12 :  PRODUCTION OF FOOTWEAR FROM FORMED UPPERS
 
 OPTION A : Yes
 
71. The manufacture of footwear of headings 64.01 to 64.05 from products including formed
uppers of any other headings is a substantial transformation.  resulting from the manufacturing
operations the input products are turned into new, different products with utility as footwear.
 
 The origin rule should be:
 
• “CTH” (THA) (MOR) (NOR) (JPN) (IND)
 
 OPTION B : Yes, provided
 
72. The manufacture of footwear of headings 64.01 to 64.05 is a substantial transformation,
provided at least 2 of the following 3 most im portant processes in footwear manufacturing are
performed: (a) making the upper unit, (b) making the sole unit, and (c) attaching operation of uppers
and sole units to form shoes.  these processes are the key determinants of the utility, quality and value
of footwear.  the country in which any two of these processes are performed should be treated as the
country of origin of the footwear so manufactured.
 G/RO/45/Ad d.2/Rev.1
Page 12
 The origin rule should be:
 
Origin of the goods of this heading is the country where at least two or more of the
following processes are undertaken: upper unit making; sole unit making; or attaching
these two units. (KOR)
 
 OPTION C : No
 
73. The manufacture of footwear of headings 64.01 to 64.05 from formed uppers of
heading 64.06 is not a substantial transformation.
 
 The origin rule should be
 
CTH with the exclusion of assembly of uppers affixed to inner or to other sole
components of heading 64.06 (EC)
 
CTH, except from formed uppers of heading 64.06 (US) (HK) (CH) (EGY)(CAN) (PHI) (AUS) (EGY)
 
CTH, except from any upper classified in 6406.10 (for footwear
 manufactured through a string lasting method); and
 
 CTH, except from formed uppers classified in 6406.10 (for other footwear)
(MEX)
 
74. As regards the term “formed uppers”, it is defined by some delegations as follows:
 
Uppers of heading 64.06 having closed bottoms, which have been shaped bylasting, moulding or otherwise, but no t by simply closing at the bottom. (US)
(HK) (CH) (EGY) (CAN) (PHI) (MEX)
 
Uppers with insole material attached to the upper, which would prevent the
base of a foot placed in the upper from coming contact with the ground.  Except
for footwear of moccasin style construction, where the upper material iscontinued under the foot to form an insole from one continuous piece of
leather. (AUS)
 
 Relevant HS codes
 Headings 64.01 to 64.05
  
ISSUE No. 13 :  PRODUCTION OF FOOTWEAR FROM UNFORMED UPPERS
 
 OPTION A : Yes
 
75. The manufacture of footwear of headings 64.01 to 64.05 from unformed uppers is a
substantial transformation.  resulting from the manufacturing operations these input products are
turned into new, different products with utility as footwear.
 
 The origin rule should be:
CTH (THA) (MOR) (NOR) (JPN) (IND)
CTH, except from formed uppers of heading 64.06 (US) (HK) (CH) (EGY) (CAN)
(PHI) (AUS) (EGY)
 G/RO/45/Ad d.2/Rev.1
Page 13
CTH, except from formed uppers classified in 6406.10 (for footwear not manufactured
through a string lasting method) (MEX)
 
CTH with the exclusion of assembly of uppers affixed to inner or to other sole
components of heading 64.06 (EC)
 
 OPTION B : Yes, provided
 
76. The manufacture of footwear of headings 64.01 to 64.05 is a substantial transformation,
provided at least 2 of the following 3 most im portant processes in footwear manufacturing are
performed: (a) making the upper unit, (b) making the sole unit, and (c) attaching operation of uppers
and sole units to form shoes.  these processes are the key determinants of the utility, quality and valueof footwear.  the country in which any two of these processes are performed should be treated as the
country of origin of the footwear so manufactured.
 
 The origin rule should be:
 
Origin of the goods of this heading is the country where at least two or more of the
following processes are undertaken: upper unit making; sole unit making; or attaching
these two units. (KOR)
 
 OPTION C: No
 
77. Obtaining footwear by manufacturing through a string lasting method from any upper is not a
substantial transformation.
 
 The origin rule should be:
 
CTH, except from any upper classified in subheading 6406.10 (MEX)
 
 Relevant HS codes
 Headings 64.01 to 64.05
 
 ISSUE No. 14 : PRODUCTION OF FOOTWEAR FROM PRODUCTS OTHER THAN UPPERS
OF CHAPTER 64
 
 OPTION A : Yes
 
78. The manufacture of footwear of headings 64.01 to 64.05 from products other than uppers of
chapter 64 is a substantial transformation.  resulting from the manufacturing operations these input
products are turned into new, different products with utility as footwear.
 
 The origin rule should be
 
CTH (THA) (MOR) (NOR) (JPN) (IND)
 
CTH, except from formed uppers of heading 64.06 (US) (HK) (CH) (EGY) (CAN)
(PHI) (AUS) (EGY)
 
CTH with the exclusion of assembly of uppers affixed to inner or to other solecomponents of heading 64.06  (EC)
 G/RO/45/Ad d.2/Rev.1
Page 14
CTH, except from any upper classified in subheading 6406.10 (for footwear
manufactured through a string lasting method); and
 
CTH, except from formed uppers classified in subheading 6406.10 (for other type of
footwear) (MEX)
 
 OPTION B : Yes, provided
 
79. The manufacture of footwear of headings 64.01 to 64.05 is a substantial transformation,
provided at least 2 of the following 3 most im portant processes in footwear manufacturing are
performed: (a) making the upper unit, (b) making the sole unit, and (c) attaching operation of uppers
and sole units to form shoes.  these processes are the key determinants of the utility, quality and valueof footwear.  the country in which any two of these processes are performed should be treated as the
country of origin of the footwear so manufactured.
 
 The origin rule should be:
 
Origin of the goods of this heading is the country where at least two or more of the
following processes are undertaken: upper unit making; sole unit making; or attaching
these two units. (KOR)
 Relevant HS codes
Headings 64.01 to 64.05G/RO/45/Ad d.2/Rev.1
Page 15
CHAPTER 64
Primary rule:
Chapter Notes:
1. Definition of "formed uppers" : Submitted to CRO for decision (Doc. 42.533, Issue No.
11)
[Uppers of Heading No. 64.06 having closed bottoms, which have been shaped by lasting,
moulding or otherwise, but not by simply cl osing at the bottom.] (US) (HK) (CH) (CAN)
(PHI) (EGY) (MEX)
[Uppers with insole material attached to the upper, which would prevent the base of a foot
placed in the upper from coming in contact with the ground.  Except for footwear of moccasin
style construction, where the upper material is continued under the foot to form an insole from
one continuous piece of leather.] (AUS)
2. For the purposes of this Chapter, those rules which refer to a change of heading or subheading
shall not apply to changes which result from disassembly.   Basket 1
[Product Specific] [Chapter] Residual Rule:    Submitted to CRO for decision (Doc. OC0023E2,
Issue No.77)
[When application of the primary rules of this chapter (including the product specific rules
provided in the matrix) does not result in a determination of a country of origin.
1. The country of origin of a good of heading 64.06 that was assembled from parts, but was not
wholly assembled in a single country, is the country in which the most significant assembly
operations were performed in the making-up of the good, without regard to the addition of buttons and
other fasteners, hanger loops, labels, foot st raps, ornaments and other minor components (US)]G/RO/45/Ad d.2/Rev.1
Page 16
Chapter 64
HS Code
NumberDescription of goods Primary rule Notes Comments
AB C D E
Chapter 64 Footwear, gaiters and the
like; parts of such articles
64.01 Waterproof footwear with
outer soles and uppers of
rubber or of plastics, the
uppers of which are neither
fixed to the sole norassembled by stitching,
riveting, nailing, screwing,
plugging or similar
processes.[CTH] (THA) (MOR) (NOR) (JPN) (IND)
[CTH, except from 
formed uppers of heading
64.06] (US) (HK) (CH)  (CAN) (PHI) (AUS)
(EGY)
[Origin of the good of this heading is thecountry where at least two or more of the
following processes are undertaken: upper
unit making; sole unit making; or attaching
these two units.] (KOR)Submitted to CRO for decision
(Doc. 42.533)
Issues 11 to 14
[CTH with the exclusion of assembly of
uppers affixed to inner or to other sole
components of heading 64.06] (EC)
[As indicated at split heading level] (MEX)
ex 64.01 (a) Footwear manufactured
through a string lasting
method[CTH, except from any upper classified insubheading 6406.10] (MEX)
ex 64.01(b) Other footwear [CTH, except from formed uppers classified
in subheading 6406.10] (MEX)
6401.10 - Footwear incorporating a
protective metal toe-capAs indicated at the heading level.
- Other footwear:
6401.91 -- Covering the knee
6401.92 -- Covering the ankle but not
covering the knee
6401.99 -- OtherG/RO/45/Ad d.2/Rev.1
Page 17HS Code
NumberDescription of goods Primary rule Notes Comments
AB C D E
64.02 Other footwear with outer
soles and uppers of rubber
or plastics.[CTH] (THA) (MOR) (NOR) (JPN) (IND)
[CTH, except from formed uppers of heading
64.06] (US) (HK) (CH)  (CAN) (PHI) (AUS)
(EGY)
[Origin of the good of this heading is the
country where at least two or more of the
following processes are undertaken: upper
unit making; sole unit making; or attachingthese two units.] (KOR)Submitted to CRO for decision
(Doc. 42.533)
Issues 11 to 14
[CTH with the exclusion of assembly ofuppers affixed to inner or to other sole
components of heading 64.06] (EC)
[As indicated at split heading level] (MEX)
ex 64.02 (a) Footwear manufactured
through a string lasting
method[CTH, except from any upper classified in
subheading 6406.10] (MEX)
ex 64.02 (b) Other footwear [CTH, except from formed uppers classified
in subheading 6406.10] (MEX)
- Sports footwear As indicated at the heading level
6402.12 -- Ski-boots, cross-country
ski footwear and snowboard
boots
6402.19 -- Other
6402.20 - Footwear with upper straps
or thongs assembled to thesole by means of plugs
6402.30 - Other footwear,
incorporating a protective
metal toe-cap
- Other footwear:
6402.91 -- Covering the ankleG/RO/45/Ad d.2/Rev.1
Page 18
HS Code
NumberDescription of goods Primary rule Notes Comments
AB C D E
6402.92 -- Other
64.03 Footwear with outer soles
of rubber, plastics, leather
or composition leather and
uppers of leather.[CTH] (THA) (MOR) (NOR) (JPN)
[CTH, except from formed uppers of heading
64.06] (US) (HK) (CH)  (CAN) (PHI) (AUS)
(EGY)Submitted to CRO for decision
(Doc. 42.533)
Issues 11 to 14
[Origin of the good of this heading is the
country where at least two or more of thefollowing processes are undertaken: upper
unit making; sole unit making; or attaching
these two units.] (KOR)
[CTH with the exclusion of assembly of
uppers affixed to inner or to other sole
components of heading 64.06] (EC)
[As indicated at split heading level] (MEX)
ex 64.03 (a) Footwear manufactured
through a string lasting
method[CTH, except from any upper classified insubheading 6406.10] (MEX)
ex 64.03 (b) Other footwear [CTH, except from formed uppers classified
in subheading 6406.10] (MEX)
- Sports footwear: As indicated at the heaving level.
6403.12 -- Ski-boots, cross-country
ski footwear and snowboard
boots
6403.19 -- Other
6403.20 - Footwear with outer soles
of leather, and uppers whichconsist of leather straps
across the instep and around
the big toeG/RO/45/Ad d.2/Rev.1
Page 19HS Code
NumberDescription of goods Primary rule Notes Comments
AB C D E
6403.30 - Footwear made on a base or
platform of wood, not having
an inner sole or a protectivemetal toe-capAs indicated at the heading level
6403.40 Other footwear,
incorporating a protective
metal toe-cap
- Other footwear with outersoles of leather:
6403.51 -- Covering the ankle
6403.59 -- Other
- Other footwear:
6403.91 -- Covering the ankle
6403.99 -- Other
64.04 Footwear with outer soles
of rubber, plastics, leather
or composition leather and
uppers of textile materials.[CTH] (THA) (MOR) (NOR) (JPN)
[CTH, except from formed uppers of heading
64.06] (US) (HK) (CH)  (CAN) (PHI) (AUS)
(EGY)
[Origin of the good of this heading is the
country where at least two or more of the
following processes are undertaken: upper
unit making; sole unit making; or attachingthese two units.] (KOR)
[CTH with the exclusion of assembly of
uppers affixed to inner or to other sole
components of heading 64.06] (EC)Submitted to CRO for decision
(Doc. 42.533)
Issues 11 to 14
[As indicated at split heading level] (MEX)
ex 64.04 (a) Footwear manufactured
through a string lasting
method[CTH, except from any upper classified in
subheading 6406.10] (MEX)G/RO/45/Ad d.2/Rev.1
Page 20
HS Code
NumberDescription of goods Primary rule Notes Comments
AB C D E
ex 64.04 (b) Other footwear [CTH, except from formed uppers classified
in subheading 6406.10] (MEX)
- Footwear with outer solesor rubber or plastics:As indicated at the heading level.
6404.11 -- Sports footwear; tennis
shoes, basketball shoes, gym
shoes, training shoes and thelike
6404.19 -- Other
6404.20 - Footwear with outer soles
of leather or composition
leather
64.05 Other footwear. [CTH] (THA) (MOR) (NOR) (JPN)
[CTH, except from formed uppers of heading64.06] (US) (HK) (CH)  (CAN) (PHI) (AUS)
(EGY)
[Origin of the good of this heading is the
country where at least two or more of the
following processes are undertaken: upperunit making; sole unit making; or attaching
these two units.] (KOR)
[CTH with the exclusion of assembly of
uppers affixed to inner or to other sole
components of heading 64.06] (EC)Submitted to CRO for decision
(Doc. 42.533)Issues 11 to 14
[As indicated at the split subheading level](MEX)
ex 64.05 (a) Footwear manufactured
through a string lasting
method[CTH, except from any upper classified in
subheading 6406.10] (MEX)
ex 64.05 (b) Other footwear [CTH, except from formed uppers classified
in subheading 6406.10] (MEX)G/RO/45/Ad d.2/Rev.1
Page 21HS Code
NumberDescription of goods Primary rule Notes Comments
AB C D E
6405.10 - With uppers of leather or
composition leatherAs indicated at the heading level.
6405.20 -  With uppers of textile
materials
6405.90 -  Other
64.06 Parts of footwear
(including uppers whether
or not attached to soles
other than outer soles);
removable in-soles, heelcushions and similar
articles; gaiters, leggings
and similar articles, and
parts thereof.As indicated at the subheading level.
6406.10 - Uppers and parts
thereof, other than stiffeners[CC] Submitted to CRO for decision
(Doc. 42.269, Issue 9))
[CTH] (EC) (CH) (EGY) (KOR) (MOR)(NOR) (JPN) (IND) (HK) (AUS) (MEX)
(PHI) (BRA) (THA)
[Proposals as indicated at the split
subheading level.] (US) (KOR)
ex 6406.10(a)-- Formed uppers
[CTSHS] (US) (CAN)
[The country where lasting operation was
performed] (KOR)G/RO/45/Ad d.2/Rev.1
Page 22
HS Code
NumberDescription of goods Primary rule Notes Comments
AB C D E
ex 6406.10
(b)-- Uppers other than formed
uppers[CTH or a change within this subheading,
provided the goods are either knit to shape or
fully assembled in one country] (US) (CAN)[The country where at least two of the
following operations were performed:
making fabric, leather, etc., cutting,
assembling parts;  or, if no country meets the
above, the country where assembly of partswas performed] (KOR)
ex 6406.10(c)-- Parts of uppers
[CTH]  (US) (KOR)
6406.20 - Outer soles and
heels, of
rubber or plasticsCTH Basket 1 (Endorsed by CRO)
-  Other
6406.91 -- Of wood CTH Basket 1 (Endorsed by CRO)
6406.99 -- Of other materials CTH Endorsed by CROG/RO/45/Ad d.2/Rev.1
Page 23CHAPTER 65
[Product Specific] [Chapter] Residual Rule:    Submitted to CRO for decision (Doc. OC0023E2, Issue No.77)
When application of the primary rules of this chapter (including the product specific rules provided in the matrix) does not re sult in a determination
of a country of origin, the country of origin shall be determined as follows:
[1. For a good of headings 65.01 through 65.05 that was assembled from parts, where the primary rule requires that the good be w holly
assembled in a single country, is the country in which the most significant assembly operations were performed in the making-up  of the good,
without regard to the addition of buttons and other fasteners, hanger loops, tighteners, labels, hat bands, ornaments and other  minor components
(US)]
HS Code
NumberDescription of goods Origin Criteria Notes Comments
AB C D E
Chapter 65 Headgear and parts thereof
65.01 Hat-forms, hat bodies and
hoods of felt, neither
blocked to shape nor with
made brims; plateaux and
manchons (including slit
manchons), of felt.CTH Basket 1 (Endored by CRO)
65.02 Hat-shapes, plaited or
made by assembling strips
of any material, neither
blocked to shape, nor withmade brims, nor lined, nor
trimmedCTH Basket 1 (Endorsed by CRO)G/RO/45/Ad d.2/Rev.1
Page 24
HS Code
NumberDescription of goods Origin Criteria Notes Comments
AB C D E
65.03 Felt hats and other felt
headgear, made from the
hat bodies, hoods orplateaux of heading No.
65.01, whether or not lined
or trimmed[CTH] (JPN) (CH) (EC) (MEX) (MAL)
(CAN) (PHI)
[CTH, provided that a blocking process hasoccurred] (IND) (KOR) (US) (AUS) (BRA)
(EGY)Submitted to CRO for decision
(Doc. 41.823, Issue 1)
65.04 Hats and other headgear,
plaited or made by
assembling strips of anymaterial, whether or not
lined or trimmed.CTH Endorsed by CRO
65.05 Hats and other headgear,
knitted or crocheted, ormade up from lace, felt or
other textile fabric, in the
piece (but   not in strips),
whether or not lined or
trimmed; hair-nets of anymaterial, whether or not
lined or trimmed.[CTH] (IND) (JPN) (CH) (EC) (CAN)
(MEX) (PHI)[CTH, provided that the goods are fully
assembled in a single country] (KOR) (US)
(EGY)Submitted to CRO for decision
(Doc. 41.823, Issue 3)
6505.10 -  Hair-nets As indicated at the heading level.
6505.90 -  Other
65.06 Other headgear, whether
or not lined or trimmed.CTH Basket 1 (Endorsed by CRO)
6506.10 - Safety headgear As indicated at the heading level.
- Other
6506.91 --  Of rubber or of plastics
6506.92 -- Of  furskin
6506.99 -- Of other materialG/RO/45/Ad d.2/Rev.1
Page 25HS Code
NumberDescription of goods Origin Criteria Notes Comments
AB C D E
65.07 Head-bands, linings, covers,
hat foundations, hat frames,
peaks and chinstraps, forheadgear.CTH Basket 1 (Endorsed by CRO)G/RO/45/Ad d.2/Rev.1
Page 26
CHAPTER 66
Chapter Notes
For the purposes of this Chapter, those rules which refer to a change of heading or subheading shall not apply to changes which  result from
disassembly.   Basket 1.
[Product Specific] [Chapter] Residual Rule:    Submitted to CRO for decision (Doc. OC0023E2, Issue No.77)
When application of the primary rules of this chapter (including the product specific rules provided in the matrix) does not re sult in a determination
of a country of origin, the country of origin shall be determined as follows:
[1. The country of origin of a good of heading 66.01 that was assembled from parts, but was not wholly assembled in a single cou ntry, is the country in
which the most significant assembly operations were performed in the making-up of the good, without regard to the addition of b uttons and other fasteners,
hanger loops, labels, ornaments and other minor components (US)]
HS Code
NumberDescription of goods Origin Criteria Notes Comments
AB C D E
Chapter 66 Umbrellas, sun umbrellas,
walking-sticks, seat-sticks,whips, riding-crops and
parts thereof
66.01 Umbrellas and sun
umbrellas (includingwalking-stick umbrellas,
garden umbrellas and
similar umbrellas).CTH Endorsed by CRO
6601.10 - Garden or similar umbrellas As indicated at the heading level.
- Other:
6601.91 -- Having a telescopic shaft
6601.99 -- OtherG/RO/45/Ad d.2/Rev.1
Page 27HS Code
NumberDescription of goods Origin Criteria Notes Comments
AB C D E
66.02 Walking-sticks, seat-sticks,
whips, riding-crops and the
like.CTH Endorsed by CRO
66.03 Parts, trimmings and
accessories of articles ofheading No. 66.01 or 66.02.CTH Basket 1 (Endorsed by CRO)
6603.10 -  Handles and knobs As indicated at the heading level.
6603.20 - Umbrella frames,
including frames mounted on
shafts (sticks)
6603.90 - OtherG/RO/45/Ad d.2/Rev.1
Page 28
CHAPTER 67
HS Code
NumberDescription of goods Origin Criteria Notes Comments
AB CD E
Chapter 67 Prepared feathers and down
and articles made of feathers or
of down; artificial flowers;
articles of human hair
67.01 Skins and other parts of birds
with their feathers or down,
feathers, parts of feathers, downand articles thereof (other than
goods of heading No. 05.05 and
worked quills and scapes)[CTH, except from heading 05.05;
or
change to articles of this headingfrom skins and other parts of birds
with their feathers or down, or from
feathers or down or parts of
feathers of this heading or of
heading 05.05][As indicated at the split heading
level]Submitted to CRO for decision
(Doc. 41.823, Issue 6)
ex 67.01(a) - Skins and other parts of birds
with their feathers or downCTH Endorsed by CRO
ex 67.01(b) - Feathers, parts of feathers, down CTHS
ex 67.01(c) - Other CTHS
67.02 Artificial flowers, foliage and
fruit and parts thereof; articles
made of artificial flowers,
foliage or fruit.[CTH] (EC) (MAL) (JPN) (MEX)
(EGY)
[As indicated at the split heading
level]Submitted to CRO for decision
(Doc. 41.823, Issue 7)
ex 67.02(a) - Artificial flowers, foliage and
fruit[CTH; or CTHS from split heading
ex67.02(b)] (IND) (PHI) (MOR)
(KOR)
ex 67.02(b) - Parts of goods in heading 67.02 [CTH] (IND) (PHI) (MOR) (KOR)G/RO/45/Ad d.2/Rev.1
Page 29HS Code
NumberDescription of goods Origin Criteria Notes Comments
AB CD E
ex 67.02(c) - Articles made of artificial
flowers, foliage or fruit[CTHS] (IND) (PHI) (MOR)
(KOR)
6702.10 -  Of plastics As indicated at the split heading
level.
6702.90 -  Of other materials
67.03 Human hair, dressed, thinned,
bleached or otherwise worked;wool or other animal hair or
other textile materials, prepared
for use in making wigs or the
like.CTH Endorsed by CRO
67.04 Wigs, false beards, eyebrows
and eyelashes, switches and the
like, of human or animal hair or
of textile materials; articles of
human hair not elsewherespecified or included.CTH Basket 1 (Endorsed by CRO)
- Of synthetic textile materials As indicated at the heading level.
6704.11 -- Complete wigs
6704.19 -- Other
__________