CFA Guidance on EBA Withdrawal

by | Aug 12, 2020 | CFA Update

On August 12, 2020, the European Commission’s decision to withdraw Everything But Arms (“EBA”)
tariff preferences for certain footwear products from Cambodia will go into effect. For the benefit of
both CFA members and international buyers, CFA has created this document to ensure that there is
clarity on the specific footwear product lines losing EBA trade benefits as well as the remaining product
lines that continue to benefit from duty-free and quota-free access to the EU market.
The European Commission’s decision on which footwear tariff lines to remove was based upon 2018
import figures. In 2018, Cambodia exported footwear amounting to a total €674 million to the EU
under 24 specific tariff lines at the six-digit level of the Harmonized System (“HS”) out of a total of 25
six-digit tariff lines under Chapters 64 of the HS.


The Commission’s February 11 decision withdraws benefits for 13 footwear tariff lines at the six-digit
level. In 2018, total Cambodian footwear exports under these lines were €210 million, or approximately
30 percent of total exports. These 13 tariff lines are provided in Table 1.


For the remaining 12 apparel tariff lines at the six-digit level, EBA duty-free and quota-free benefits
remain in effect beyond August 12, 2020. These 12 tariff lines are provided in Table 2

Table 1: Tariff Lines Suspended from EBA Effective August 12, 2020

HS CodeHS DescriptionMFN Duty
640319Sports footwear; (other than ski-boots, snowboard boots or cross-country ski
footwear), with outer soles of rubber, plastics, leather or composition leather and
uppers of leather
8%
640320Footwear; with metal toe-cap, outer soles of rubber, plastics, leather or
composition leather, uppers of leather
8%
640340Footwear; n.e.c. in heading no. 6403, with outer soles and uppers of leather,
covering the ankle
8%
640351Footwear; n.e.c. in heading no. 6403, (not covering the ankle), outer soles and
uppers of leather
8%
640359Footwear; n.e.c. in heading no. 6403, covering the ankle, outer soles of rubber,
plastics or composition leather, uppers of leather
5-8%
640391Footwear; n.e.c. in heading no. 6403, (not covering the ankle), outer soles of
rubber, plastics or composition leather, uppers of leather
5-8%
640399Footwear; n.e.c. in heading no. 6403, (not covering the ankle), outer soles of
rubber, plastics or composition leather, uppers of leather
5-8%
640510Footwear; with uppers of leather or composition leather, n.e.c. in chapter 643.5%
640520Footwear; with uppers of textile materials, n.e.c. in chapter 643.50-4%
640590Footwear; n.e.c. in chapter 644-17%
640610Footwear; parts, uppers and parts thereof, other than stiffeners3%
640620Footwear; parts, outer soles and heels, of rubber or plastics3%
640690Footwear; parts, n.e.c. in heading 64063%

Table 2: Tariff Lines that Maintain EBA Benefits

HS CodeHS DescriptionMFN DutyEBA Duty
640110Footwear; waterproof with metal toe-cap, rubber, or plastic outer soles
and uppers (not assembled by stitch, rivet, nail, screw, plug, or similar)
17%0%
640192Footwear; waterproof, covering the ankle (but not the knee), rubber or plastic outer soles and uppers (not assembled by stitch, rivet, nail, screw, plug, or similar)17%0%
640199Footwear; waterproof, n.e.c. in heading no. 6401, rubber or plastic outer soles and uppers (not assembled by stitch, rivet, nail, screw, plug or similar)17%0%
640212Sports footwear; with outer soles and uppers of rubber or plastics, ski-boots, cross-country ski footwear, and snowboard boots17%0%
640219Sports footwear; (other than ski boots, snowboard boots or cross-country ski footwear), with outer soles and uppers of rubber or plastics16.9%0%
640220Footwear; with outer soles and uppers of rubber or plastics, upper straps or thongs assembled to the sole by plug17%0%
640291Footwear; n.e.c. in heading no. 6402, covering the ankle, with outer soles and uppers of rubber or plastics16.9-17%0%
640299Footwear; n.e.c. in heading no. 6402, (other than just covering the ankle), with outer soles and uppers of rubber or plastics16.8-17%0%
640312Ski-boots, cross-country, ski footwear, and snowboard boots8%0%
640411Sports footwear; tennis shoes, basketball shoes, gym shoes, training
shoes and the like, with outer soles of rubber or plastics and uppers of
textile materials
16.9%0%
640419Footwear; (other than sportswear), with outer soles of rubber or
plastics and uppers of textile materials
16.9%0%
640420Footwear; outer soles of leather or composition leather, uppers of
textile materials
17%0%