CLA-2 CO:R:C:G 088194 DFC
Mr. Carl Davis,
Director, Trade Operations
One Bowerman Drive
Beaverton, OR 97005-6453
RE: Standards for measuring plastic coating on leather.
Dear Mr. Davis:
In a letter dated November 2, 1990, you inquired as to
what formal testing procedure and standards are applied by
the U.S. Customs Service in measuring the thickness of plastic
coating on footwear leather.
You have posed 5 specific questions. We will reply to
questions 1 and 5 separately. Since the answers to questions
2 through 4 are dependent on each other, we will respond to
them jointly.
Question No 1: Is the Satre method to be used?
The method used by U.S. Customs laboratories is described
below. We are not aware of a method known specifically as
the "Satre" method. We are aware of a British method for
measuring thickness of surface coatings on leather. An
organization known as the Satra Footwear Technology Centre
participated in the development of the procedure. The U.S.
Customs method and the British method are similar.
Question No. 2: How many tests should be performed
on a standard shoe?
Question No. 3: Where, on a shoe, should the samples
be taken?
-2-
Question No. 4: If the samples vary in thickness,
will Customs take an average of the
tests or apply some other standard?
Three to five individual measurements are taken on every
portion of the shoe that is different. For example, if a
shoe is constructed of only one piece of leather, then five
measurements are taken. If a shoe is constructed of several
pieces of leather that are attached, then 3 to 5 measurements
on each of the several pieces are taken and averaged. A
"different piece" can simply be a different color placed on
the same piece of leather. Measurements are taken at
representative sites on each different piece of leather. Care
is taken to avoid areas that are deformed either due to
construction of the article or due to imperfections in the
leather. The measurements are averaged to arrive at a final
result.
Question No. 5: If the coating is laminated on
the leather, will the adhesive be
included or excluded from the
measurement?
Under our procedures, the adhesive is not being included
in the measurement of the thickness of a laminated coating.
Sincerely,
John Durant, Director
Commercial Rulings Division
6cc AD NY Seaport
1cc Dist Dir Portland Oregon
1cc Eric Francke NY Seaport
1cc Legal Reference
cahill library/peh
088194