OT:RR:CTF:CPMMA H361779 SRH
TARIFF Nos.: 8205.59.5560 and 8205.59.7000
Ms. Jennifer M. Smith-Veluz
Butzel Long, P.C.
1909 K Street, NW, Suite 860
Washington, DC 20006
Re: Request to reconsider NY N361167; Tariff Classification of Various Cam Levers
Dear Ms. Smith-Veluz:
This letter is in response to your correspondence, dated June 23, 2026, on behalf of NK
North America Inc. (“NK”), formerly KIPP Inc. (“KIPP”), requesting reconsideration of New
York Ruling Letter (“NY”) N361167, dated May 15, 2026, concerning the tariff classification of
five cam levers, model numbers K0005.25011A3, K0005.2501110X40, K0006.15011A2X20,
K2120.15011A2 and K0647.15120A2X20. In NY N361167, U.S. Customs and Border
Protection (“CBP”) classified the subject merchandise under subheadings 7326.90.8688 and
7616.99.5190 of the Harmonized Tariff Schedule of the United States Annotated (“HTSUSA”).
Subheading 7326.90.8688, HTSUSA, provides for “Other articles of iron or steel: Other: Other:
Other: Other: Other” and subheading 7616.99.5190, HTSUSA, provides for “Other articles of
aluminum: Other: Other: Other: Other: Other.”
In your reconsideration request, you assert that this classification is incorrect, and that the
subject merchandise is correctly classifiable under subheading 8466.20.8065, HTSUSA, which
provides for “Parts and accessories suitable for use solely or principally with the machines of
headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads
and other special attachments for the machines; tool holders for any type of tool for working in
the hand: Work holders: Other: Other work holders: Other.” Alternatively, you assert that the
subject merchandise is correctly classifiable under subheading 8205.59.5560, HTSUSA, which
provides for “Handtools (including glass cutters) not elsewhere specified or included; blow
torches and similar self-contained torches; vises, clamps and the like, other than accessories for
and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-
operated grinding wheels with frameworks; base metal parts thereof: Other handtools (including
glass cutters) and parts thereof: Other: Other: Of iron or steel: Other: Other (including parts); and
subheading 8205.59.7000, HTSUSA, which provides for “Handtools . . . Other: Of aluminum.”
You requested that certain information submitted in connection with this request -
specifically identified confidential commercial and business proprietary information of NK (in
particular, technical drawings) - be treated as confidential. Inasmuch as this request conforms to
the requirements of 19 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. The
specified information will not be released to the public and will be withheld from the published
version of this decision.
We have reviewed NY N361167 and determined that it erroneously classified the cam
levers at issue. Therefore, this ruling serves to revoke NY N361167 as explained below. As this
revocation decision is being issued within 60 days of the issuance of NY N361167, pursuant to
19 U.S.C. § 1625(c)(1) and 19 C.F.R. § 177.12(b), this revocation is effective immediately.
FACTS:
The subject merchandise was described in NY N361167 as follows:
The items under consideration are cam levers, model numbers K0005.25011A3,
K0005.2501110X40, K0006.15011A2X20, K2120.15011A2 and K0647.15120A2X20. These
devices are used to brace and hold objects in place to prevent movement.
Each model is equipped with a metal waved handle housing a hinge pin attached to a washer
assembly. In this ruling, there are two types of cam levers: male cam levers (K0005.2501110X40,
K0006.15011A2X20, K0647.15120A2X20) and female cam levers (K0005.25011A3,
K2120.15011A2). The male cam levers have threaded studs extending from the bottom of their
washer assemblies, while the female cam levers have openings in their washer assemblies with
internal threading. When in use, a male cam lever can be applied like a screwdriver using the stud
and handle. A female cam lever secures its objects using its internal threading to secure itself to a
male stud outside its assembly. Once the washer assembly is flush with an object, the cam lever
can be tightened with the leverage of the handle and hold that object in place.
The five cam levers at issue are composed of several components and consist of multiple
materials. A breakdown of the components and materials for each of the five cam levers is
provided below:
Model K0005.25011A3:
- Aluminum handle, internal thread, steel components, 2-part washer.
- Total percent weight of material: Aluminum (76%), Steel (21%), Other (3%).
Model K0005.2501110X40:
- Aluminum handle, external thread, steel components, 2-part washer.
- Total percent weight of material: Aluminum (58%), Steel (39%), Other (4%).
Model K0006.15011A2X20:
- Aluminum handle, external thread, adjustable, steel components, 2-part washer.
- Total percent weight of material: Aluminum (55%), Steel (42%), Other (3%).
2
Model K2120.15011A2:
- Aluminum handle, internal thread, steel components, all-plastic washer.
- Total percent weight of material: Aluminum (76%), Steel (21%), Other (3%).
Model K0647.15120A2X20:
- Stainless steel handle, external thread, adjustable, stainless components, 2-part washer.
- Total percent weight of material: Aluminum (0%), Steel (99%), Other (1%).
Images of two of the cam levers at issue—one external thread (male), and one internal
thread (female)—are included below.
K0006.15011A2X20 (External Thread) K0005.25011A3 (Internal Thread)
Image 1 Image 2
Information from NK’s website further describes the cam levers and provides details on
their main components:
Cam levers are operating parts that are used for quick and torque-free clamping of workpieces. It
uses an eccentrically mounted axle to generate sufficient clamping force when actuated. This
property makes it a versatile tool in many technical and industrial applications.
Cam levers consist of the following main components:
Lever arm: The lever arm is the main part of the cam lever. It serves as a handle and facilitates
power transmission. It is made of a sturdy material such as steel or plastic and can be
ergonomically shaped to make handling easier. The clamping force is generated by moving the
lever arm.
Eccentric axle: An eccentric axle is an axle that is mounted off-centre in the lever. It enables the
actual clamping or fastening movement and is therefore the centrepiece of the cam lever. This off-
centre axis converts the rotary movement of the lever arm into a linear movement that moves the
clamping plate towards or away from the workpiece.
Bearing or pivot point: The pivot point is the area around which the lever arm moves. Bearings
are often built-in to enable low-friction movement. The pivot point enables the lever arm to rotate
and supports the eccentric axis to precisely carry out the movements.
3
Clamping plate: A clamping plate is that part of the cam lever that presses directly onto the
workpiece. It can be made of metal, plastic or other materials and often has a non-slip surface. The
clamping plate transfers the generated force to the workpiece and holds it securely against the
counter bearing. 1
In describing the potential uses of the cam levers that they sell, NK states that “they are
used in machine and plant construction, in toolmaking, and in medical and rehabilitation
technology,” and that “[t]hey are perfect for applications that require fast and secure fastening,
such as in the machine tool industry, in plant engineering or assembly technology.” Id.
ISSUE:
What is the proper classification of the subject cam levers?
LAW AND ANALYSIS:
The classification of goods under the HTSUS is governed by the General Rules of
Interpretation (“GRIs”). GRI 1 provides that classification shall be determined according to the
terms of the headings of the tariff schedule and any relative section or chapter notes. In the event
that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal
notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order.
The HTSUS headings and subheadings (where applicable) under consideration are as
follows:
7318 Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins,
washers (including spring washers) and similar articles, of iron or steel:
7326 Other articles of iron or steel:
7616 Other articles of aluminum:
7616.10 Nails, tacks, staples (other than those of heading 8305), screws, bolts,
nuts, screw hooks, rivets, cotters, cotter pins, washers and similar
articles:
7616.99 Other:
Other:
8205 Handtools (including glass cutters) not elsewhere specified or included; blow
torches and similar self-contained torches; vises, clamps and the like, other than
accessories for and parts of machine tools or water-jet cutting machines; anvils;
portable forges; hand- or pedal-operated grinding wheels with frameworks; base
metal parts thereof:
1
KIPP, Cam Levers, https://www.kippusa.com/en-us/products/METRIC/Adjustable-handle-tension-lever-cam-
lever/Cam-levers/c/20964?srsltid=AfmBOorZcmTv-z7ZpB_VbGFTERSNXxSmSdJYEpSL9wIIb_Hi9RhScTBU
(last visited July 1, 2026).
4
8466 Parts and accessories suitable for use solely or principally with the machines of
headings 8456 to 8465, including work or tool holders, self-opening dieheads,
dividing heads and other special attachments for the machines; tool holders for
any type of tool for working in the hand:
Note 1 to Section XV, HTSUS states, in pertinent part:
1. This Section does not cover:
…
(f) Articles of Section XVI (machinery, mechanical appliances and electrical goods);
Note 2 to Section XV, HTSUS states:
2. Throughout the tariff schedule, the expression “parts of general use” means:
(a) Articles of heading 73.07, 73.12, 73.15, 73.17 or 73.18 and similar articles of other
base metal, other than articles specially designed for use exclusively in implants in
medical, surgical, dental or veterinary sciences (heading 90.21);
(b) Springs and leaves for springs, of base metal, other than clock or watch springs
(heading 9114); and
(c) Articles of heading 8301, 8302, 8308 or 8310 and frames and mirrors, of base metal,
of heading 8306.
In chapters 73 to 76 and 78 to 82 (but not in heading 7315) references to parts of goods do not
include references to parts of general use as defined above.
Subject to the preceding paragraph and to Note 1 to Chapter 83, the articles of Chapter 82 or 83
are excluded from Chapters 72 to 76 and 78 to 81.
Note 1 to Section XVI, HTSUS states, in pertinent part:
1. This section does not cover:
…
(g) Parts of general use, as defined in note 2 to section XV, of base metal (section XV),
or similar goods of plastics (chapter 39);
…
(k) Articles of chapter 82 or 83[.]
Note 2 to Section XVI, HTSUS states:
2. Subject to Note 1 to this Section, Note 1 to Chapter 84 and Note 1 to Chapter 85, parts of
machines (not being parts of the articles of heading 84.84, 85.44, 85.45, 85.46 or 85.47) are to be
classified according to the following rules:
(a) Parts which are goods included in any of the headings of Chapter 84 or 85 (other
than headings 84.09, 84.31, 84.48, 84.66, 84.73, 84.87, 85.03, 85.22, 85.29, 85.38 and
85.48) are in all cases to be classified in their respective headings;
(b) Other parts, if suitable for use solely or principally with a particular kind of machine,
or with a number of machines of the same heading (including a machine of heading 84.79
or 85.43) are to be classified with the machines of that kind or in heading 84.09, 84.31,
84.48, 84.66, 84.73, 85.03, 85.22, 85.29 or 85.38 as appropriate. However, parts which
5
are equally suitable for use principally with the goods of headings 85.17 and 85.25 to
85.28 are to be classified in heading 85.17, and parts which are suitable for use solely or
principally with the goods of heading 85.24 are to be classified in heading 85.29;
(c) All other parts are to be classified in heading 84.09, 84.31, 84.48, 84.66, 84.73,
85.03, 85.22, 85.29 or 85.38 as appropriate or, failing that, in heading 84.87 or 85.48.
Note 2 to Chapter 82, HTSUS, states, in relevant part:
Parts of base metal of the articles of this Chapter are to be classified with the articles of which they
are parts, except parts separately specified as such and tool-holders for hand tools (heading 84.66).
However, parts of general use as defined in Note 2 to Section XV are in all cases excluded from
this Chapter.
In addition, in interpreting the HTSUS, the Explanatory Notes (“ENs”) of the
Harmonized Commodity Description and Coding System may be utilized. The ENs, although
neither dispositive nor legally binding, provide a commentary on the scope of each heading, and
are generally indicative of the proper interpretation of the HTSUS at the international level. See
T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989).
Explanatory Note (C) to Section XV provides:
In general, identifiable parts of articles are classified as such parts in their appropriate headings in
the Nomenclature.
However, parts of general use (as defined in Note 2 to this Section) presented separately are not
considered as parts of articles, but are classified in the headings of this Section appropriate to
them. This would apply, for example, in the case of bolts specialised for central heating radiators
or springs specialised for motor cars. The bolts would be classified in heading 73.18 (as bolts) and
not in heading 73.22 (as parts of central heating radiators). The springs would be classified in
heading 73.20 (as springs) and not in heading 87.08 (as parts of motor vehicles).
Explanatory Note 7 to Section XV states:
7. Classification of composite articles:
Except where the headings otherwise require, articles of base metal (including articles of
mixed materials treated as articles of base metal under the General Interpretative Rules) containing
two or more base metals are to be treated as articles of the base metal predominating by weight
over each of the other metals.
EN 82.05 states, in pertinent part:
This heading covers all hand tools not included in other headings of this Chapter or elsewhere in
the Nomenclature (see the General Explanatory Notes to this Chapter), together with certain other
tools or appliances specifically mentioned in the title.
It includes a large number of hand tools (including some with simple hand operated mechanisms
such as cranks, ratchets or gearing). This group of tools includes:
…
(D) Screw drivers (including ratchet types).
…
(G) Vices, clamps and the like
6
EN 84.66 states, in pertinent part:
With the exception of the tools of Chapter 82 and subject to the general provisions regarding the
classification of parts (see the General Explanatory Note to Section XVI), this heading covers:
(A) Parts of the machines of headings 84.56 to 84.65.
(B) Accessories for these machines, that is, subsidiary devices used in connection with the
machines, such as interchangeable devices which modify the machine so that it can perform a
wider range of operations; devices to increase precision; devices which perform a particular
service relative to the main function of the machine.
(C) Tool holders for any type of tool for working in the hand.
The very wide range of parts and accessories classified here includes:
(1) Tool holders which hold, guide or operate the working tool and which permit the
interchange of such tool-pieces. They are of very varied types, e.g.:
Chucks; tap and drill collets; lathe tool posts; self-opening dieheads; grinding wheel holders;
honing bodies for use in honing machines; boring bars; turrets for turret lathes, etc.
This heading also includes tool holders for any type of tool designed for operation in the hand.
Such holders are usually designed for the tools of heading 82.05 or 84.67, but this heading also
includes tool holders for flexible shaft outfits. (See also the provisions of the Explanatory Notes
to headings 84.67 and 85.01).
(2) Work holders designed to hold and sometimes manipulate (as required for a particular
operation) the part being worked by the machine.
A. Classification Under Headings 7318 and 7616, HTSUS, as Parts of General Use
Initially, CBP must determine whether the subject cam levers are “parts of general use”
as defined by Note 2(a) to Section XV. Note 1(f) to Section XV (which covers chapter 73),
excludes “articles of Section XVI.” Note 1(g) to Section XVI (which covers chapter 84),
excludes “parts of general use, as defined in Note 2 to Section XV, of base metal.” It follows
that, if the instant merchandise is properly classified as “parts of general use” under heading
7318, Note 1(g) to Section XVI precludes their classification under heading 8466, HTSUS.
Therefore, we must consider whether the instant merchandise is properly classified as a “part of
general use.” While numerous headings fall under the definition of “parts of general use,” the
headings at issue here are heading 7318, HTSUS, which provides for “screws, bolts, nuts . . . and
similar articles” of iron or steel, and subheading 7616.10, HTSUS, which provides for “screws,
bolts, nuts . . . and similar articles” of aluminum. 2
2
While subheading 7616.10, HTSUS, is not specifically listed in Note 2(a) to Section XV, it is included under the
umbrella of “parts of general use” because Note 2(a) to Section XV includes “similar article of other base metal.”
Articles of subheading 7616.10, HTSUS, are made of aluminum, which meets the definition of “base metal” as
defined in Note 3 to Section XV, and they are similar to articles of heading 7318, HTSUS. Articles of subheading
7616.10, HTSUS, are made of aluminum, which meets the definition of “base metal” as defined in Note 3 to Section
XV, and they are similar to articles of heading 7318, HTSUS.
7
There is no question that the subject cam levers have the characteristics of a fastener, in
that they are used to brace and hold something in place. The key issue here is whether the cam
levers meet the definition of screws, bolts, nuts, and similar articles, under heading 7318,
HTSUS. Explanatory Note 73.18 defines screws, bolts, and nuts, stating that they “are threaded
(in the finished state) and are used to assemble or fasten goods so that they can readily be
disassembled without damage.” As discussed above, the subject cam levers have both internal
and external threading. The cam levers with external threading are analogous to screws, which
were specifically defined in Rocknel Fastener v. United States, 24 C.I.T. 900 (Ct. Int’l Trade
2000): “[A] screw [is defined] as ‘an externally threaded fastener capable of being inserted into
holes in assembled parts, of mating with a preformed internal thread or forming its own thread,
and of being tightened or released by torquing the head.’” The cam levers with internal
threading are analogous to nuts. In Headquarters Ruling Letter (“HQ”) H293256, dated June 3,
2019, CBP defined a “nut” broadly as “a type of fastener which is internally threaded and often
used opposite a mating bolt, holding the bolt in place and thus fastening the materials together.”
Solely considering the portions of the cam levers consisting of the threaded studs
(external threading) and the open washer assemblies (internal threading) may indicate that they
should be classified as “screws” and “nuts,” and CBP has classified items called “cam fasteners”
as “parts of general use” under heading 7318, HTSUS. See HQ H263900, dated October 19,
2016 (discussing prior rulings where steel cam fasteners were found to have the design
characteristics of a screw and were therefore classified in heading 7318, HTSUS). However, as
discussed above, the subject cam levers consist of several components, only one of which is the
threaded component. The main component of the subject cam levers is not the threaded
component. Instead, it is the lever arm/handle, which serves as a handle and allows the articles
to be worked in the hand, facilitates power transmission, and generates the clamping force
necessary to fasten the item being held in place. It is similar to a screwdriver or wrench which
acts upon screws and nuts to provide torquing force, and it is essential to the functioning of the
subject cam levers. The lever arm/handle component constitutes a significant design and
functional element which distinguishes the subject cam levers from the “cam fasteners”
discussed in HQ H263900, supra, and removes the cam levers from falling under the definition
of “screws,” “bolts,” or similar items as “parts of general use.” Therefore, the subject cam levers
are not classifiable as “parts of general use” under either heading 7318 or 7616, HTSUS.
B. Classification Under Heading 8466, HTSUS, as Tool Holders for Any Type of
Tool for Working in the Hand
As set forth above, Note 1(f) to Section XV (Chapter 82) excludes articles of Section
XVI (Chapter 84) while Note 1(k) to Section XVI excludes articles of Chapters 82 or 83.
Considering both exclusionary notes together, Note 1(f) to Section XV excludes articles of
Section XVI unless the subject merchandise is an article of Chapters 82 or 83. 3 However, Note 2
to Chapter 82 excludes, in relevant part, “tool-holders for hand tools (heading 84.66).”
Therefore, before considering whether the subject merchandise is an article of Chapter 82, CBP
must first determine whether the subject cam levers are classifiable under heading 8466, HTSUS,
as “tool holders for any type of tool for working in the hand.”
3
The EN to 84.66 also indicates that the tools of Chapter 82 are excluded from the heading.
8
EN 84.66 indicates that tool holders for any type of tool designed for operation in the
hand “are usually designed for the tools of heading 82.05 or 84.67, but this heading also includes
tool holders for flexible shaft outfits.” The subject cam levers are designed for the clamping of
workpieces, and they are used to brace and hold objects in place to prevent movement. They are
not tool holders. Therefore, they are not considered tool holders for any type of tool designed for
operation in the hand, nor are they tool holders for flexible shaft outfits. Thus, the cam levers are
not classifiable under heading 8466, HTSUS, as “tool holders for any type of tool for working in
the hand.”
C. Classification Under Heading 8205, HTSUS, as Handtools
Based on the finding above, and the reading of Note 1(f) to Section XV and Note 1(k) to
Section XVI, the next line of inquiry focuses on whether the subject cam levers are classifiable
as hand tools under heading 8205, HTSUS, which provides in pertinent part for “handtools . . .
not elsewhere specified or included; base metal parts thereof.” The ENs to Chapter 82 state that,
in general, “the Chapter covers tools which can be used independently in the hand, whether or
not they incorporate simple mechanisms such as gearing, crank-handles, plungers, screw
mechanisms or levers.” Further, Note 1 to Chapter 82 states, in pertinent part, “this Chapter
covers only articles with a blade, working edge, working surface or other working part of: (a)
Base metal.” EN 82.05 states, in pertinent part, that this heading “includes a large number of
hand tools (including some with simple hand-operated mechanisms such as cranks, ratchets or
gearing)” and the group of tools includes “screw drivers” and “vices, clamps, and the like.”
As discussed above, the cam levers at issue are operated independently by hand—they
are grasped by the hand, torqued to desired pressure by hand, and then force is applied by hand
to the lever, which generates the necessary clamping force to lock the cam lever with pressure in
place.
The term “tool” is not defined in the HTSUS. In the absence of a definition provided in
the HTSUS, a term must be construed in accordance with its common meaning, which may be
ascertained by reference to “dictionaries, scientific authorities, other reliable information
sources,” “lexicographic and other materials” and to the pertinent ENs. See C.J. Tower & Sons
v. United States, 69 C.C.P.A. 128, 673 F.2d 1268, 1271 (1982); Simod America Corp. v. United
States, 872 F.2d 1572, 1576 (Fed. Cir. 1989); GRK Can., Ltd. v. United States, 761 F.3d 1354,
1357 (Fed. Cir. 2014). A review of dictionaries and other reliable sources indicates that the
common meaning of “tool” is sufficiently encompassed by the definition provided by Merriam-
Webster: “a handheld device that aids in accomplishing a task” Tool, Merriam-Webster.com,
https://www.merriam-webster.com/dictionary/tool (last visited July 6, 2026); see also, Tool,
Oxford English Dictionary, https://www.oed.com/dictionary/tool_n?tab=meaning_and
_use#17984326 (“‘Any instrument of manual operation’ (Johnson); a mechanical implement for
working upon something, as by cutting, striking, rubbing, or other process, in any manual art or
industry; usually, one held in and operated directly by the hand (or fixed in position, as in a
lathe), but also including certain simple machines, as the lathe; sometimes extended to simple
instruments of other kinds.”). The subject cam levers fit within these common definitions of
“tools.” They are devices/instruments operated by the hand that are used to assist with bracing
and holding objects in place. Moreover, the description of the subject cam levers provided on
9
NK’s website above describes them in part as “versatile tool[s],” 4 further supporting the finding
that they meet the definition of hand tools.
The Chapter Notes for Chapter 82, HTSUS, state that, with certain exceptions, “this
chapter covers only articles with a blade, working edge, working surface or other working part
of: (a) Base metal[.]” Thus, the conclusion that the cam levers are “hand tools,” by itself, is not
sufficient to warrant classification under Chapter 82, HTSUS. They must also be found to have a
blade, working edge, working surface or other working part of base metal. The court in
Continental Arms Corp. v. United States, 65 Cust. Ct. 80, 84 (U.S. 1970) defined “working part”
as “that part of the tool which does work in relation to a workpiece or object external to the tool.”
In coming to this definition, the court referenced Webster’s New International Dictionary, stating
“[w]ork is done when there is movement against a resisting force or when a body is given
acceleration.” Continental Arms Corp, 65 Cust. Ct. at 84. Turning to the subject cam levers
with this definition in mind, the “working part” is the portion of the cam lever that acts upon an
external object when force is applied with the lever component. For the “male” cam levers, force
is mainly transmitted to the external object by torquing the lever component through the
externally threaded studs, and for the “female” cam levers, force is mainly transmitted to the
external object by torquing the lever component through the internal threading. The
internal/external threaded portions of the subject cam levers are in direct contact with objects
external to the tool, and force is maintained via this direct contact with the lever component in
the set and locked position. The threaded portions of the five subject cam levers are all of base
metal, and therefore, the main working part is of base metal.
Additionally, force is also transmitted to objects external to the tool through the clamping
plate component of the cam levers. Information you provided indicates that for four of the five
cam levers at issue, the clamping plate, also called the thrust washer, consists of a steel bottom
plate, a polyamide top plate, and a rubber sheet in between. For these four cam levers, the steel
bottom plate (of base metal) is the working part of the clamping plate component. One of the
cam levers, K2120.15011A2, consists of an entirely plastic washer. However, the cam lever is
otherwise made entirely of metal, and the purpose of an all-plastic washer appears to be to limit
damage to the external object in contact with the cam lever thrust washer. This is analogous to a
metal vice with non-metallic jaw grips to prevent damage to the piece being held, and EN
82.05(G) states that such metal vices with non-metallic jaw grips are included in heading 8205,
HTSUS (despite the working surface being faced with a material other than metal). Therefore,
the exception provided in EN 82.05(G) also applies to a metal cam lever with a plastic washer
like K2120.15011A2. According to Note 1(a) of Chapter 82, an article that has a working
surface or other working part that is of base metal is classifiable under Chapter 82. Thus, the
five cam levers at issue are prima facie classifiable under Chapter 82.
Heading 8205, HTSUS, covers “Handtools (including glass cutters) not elsewhere
specified or included; blow torches and similar self-contained torches; vises, clamps and the like,
other than accessories for and parts of machine tools or water-jet cutting machines; anvils;
portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts
4
KIPP, Cam Levers, https://www.kippusa.com/en-us/products/METRIC/Adjustable-handle-tension-lever-cam-
lever/Cam-levers/c/20964?srsltid=AfmBOorZcmTv-z7ZpB_VbGFTERSNXxSmSdJYEpSL9wIIb_Hi9RhScTBU
(last visited July 1, 2026).
10
thereof.” The EN for heading 8205, HTSUS, explains how this heading covers all hand tools not
included elsewhere, and how it includes a large number of hand tools (some with simple hand-
operated mechanisms 5) including screwdrivers and vices, clamps, and the like. In evaluating the
proper classification of tools under heading 8205, HTSUS, CBP explained in HQ H070916,
dated July 17, 2014, that “the terms of heading 8205 limit this heading to the type of tools where
a person uses his/her hands to utilize the tool to perform the work.” The tariff terms
“screwdriver” and “vices, clamps, and the like” are not defined in the HTSUS, but the common
meaning of these terms has been elucidated by CBP and the courts. As discussed below, the
subject cam levers do not meet the specific, common meaning definitions and are not eo nomine
classifiable as screwdrivers or vices, clamps and the like; however, they do share significant
similarities, and as hand tools not elsewhere specific or included—where a person uses their
hands to utilize the tool to perform the work—classification in heading 8205, HTSUS, is
appropriate.
In Irwin Indus. Tool Co. v. United States, 222 F. Supp. 3d 1210, 1226 (Ct. Int’l Trade
2017) the court defined “vises, clamps and the like” as “a tool composed of a frame and two
opposing jaws, at least one of which is adjustable, which are tightened together usually with a
screw, lever, or thumbnut, to press firmly on an object and hold the object securely in place
while the user is working.” The cam levers do not meet this definition entirely because they do
not have two opposing jaws, but there are significant similarities in that they are operated and
tightened with a screw and lever, and they act to brace and hold an object securely in place.
Further, in HQ H070915, dated July 17, 2014, CBP defined “screwdriver” as a “tool for turning
screws.” The cam levers are not tools for turning screws, but again there are functional
similarities. As acknowledged in NY N361167, supra, a male cam lever can be “applied like a
screwdriver using the stud and handle.” The cam levers are initially secured into place by
turning them by hand, similar to how a screwdriver is used. Thus, while cam levers are not
specifically named in the EN to heading 8205, HTSUS, they share significant similarities in form
and function with several of the hand tools described in the EN, and are properly classifiable as
hand tools in heading 8205, HTSUS, which covers all hand tools not included in other headings
of Chapter 82 or elsewhere in the Nomenclature.
Note 3, Section XV, HTSUS, provides, in pertinent part, that throughout the tariff
schedule, the expression “base metals” includes steel and aluminum. Note 7, Section XV,
HTSUS, governs the classification of articles composed of two or more base metals, and states:
Except where the headings otherwise require, articles of base metal (including articles of
mixed materials treated as articles of base metal under the General Interpretative Rules) containing
two or more base metals are to be treated as articles of the base metal predominating by weight
over each of the other metals.
With respect to the subject five cam levers, for all but one, the aluminum components
account for the majority of the weight (between 55% and 76% of the total weight) as compared
to the steel components (between 21% to 39% of the total weight). Therefore, consistent with
Note 7, Section XV, HTSUS, as aluminum predominates by weight over each of the other
metals, these four cam levers are treated as articles of aluminum. The proper classification of
5
The lever handle component of the cam levers can be considered a simple hand-operated mechanism.
11
these four cam levers (Models K0005.25011A3, K0005.2501110X40, K0006.15011A2X20, and
K2120.15011A2) is under heading 8205.59.7000, HTSUSA, which provides for “Handtools
(including glass cutters) not elsewhere specified or included . . .; base metal parts thereof: Other
handtools (including glass cutters) and parts thereof: Other: Other: Of aluminum.”
The remaining cam lever, Model K0647.15120A2X20, consists only of one base metal:
steel. Therefore, this cam lever is an article of steel. The proper classification of this cam lever
is under heading 8205.59.5560, HTSUSA, which provides for “Handtools (including glass
cutters) not elsewhere specified or included . . .; base metal parts thereof: Other handtools
(including glass cutters) and parts thereof: Other: Other: Of iron or steel: Other: Other (including
parts).”
D. Classification Under Heading 8466, HTSUS, as Parts and Accessories Suitable
for Use Solely with the Machines of Headings 8456–8465
The subject cam levers are classifiable in Chapter 82 and specifically under heading
8205, HTSUS, and therefore, given the exclusionary language in Note 1(k) to Section XVI, they
must be classified under heading 8205, HTSUS, and cannot be classified under heading 8466,
HTSUS. However, for the sake of completeness, CBP will address whether the subject cam
levers could have been classified under heading 8466, HTSUS, as “parts and accessories suitable
for use solely or principally with the machines of headings 8456 to 8465, including work or tool
holders” if they had not been found to be classifiable as handtools under heading 8205, HTSUS.
EN 84.66 indicates that “work holders” classified under heading 8466, HTSUS are
“designed to hold and sometimes manipulate (as required for a particular operation) the part
being worked by the machine” and they “include” items such as “clamps” and “fixed, revolving
or adjustable machine vices.” To be classifiable under heading 8466, HTSUS, the subject cam
levers must be “[p]arts and accessories suitable for use solely or principally with the machines of
headings 8456 to 8465.” These headings cover machine tools used to shape, cut, or otherwise
process materials like metal, wood, glass, and stone by removing or modifying materials.
The subject cam levers are not classifiable under heading 8466, HTSUS, because there is
no evidence that they are used solely or principally with the machines of headings 8456 to 8465,
HTSUS. You have provided examples of the cam levers being used with the machines of
headings 8456 to 8465, HTSUS, but have not provided evidence showing that this is their sole or
principal use. Importantly, no evidence has been provided showing that there is anything
specific with these cam levers that allows them to function only with the machines of headings
8456 to 8465, HTSUS. Statements from NK’s website highlight their general applications and
do not support the contention that they are used solely or principally with the machines of
headings 8456 to 8465. For example, in describing their cam levers (including the five cam
levers currently at issue), the website states that they are a “versatile tool in many technical and
industrial applications . . . [and] their ability to quickly and safely carry out fastening and
adjustment processes makes them an efficient solution for many industrial and technical tasks.” 6
6
KIPP, Cam Levers, https://www.kippusa.com/en-us/products/METRIC/Adjustable-handle-tension-lever-cam-
lever/Cam-levers/c/20964?srsltid=AfmBOorZcmTv-z7ZpB_VbGFTERSNXxSmSdJYEpSL9wIIb_Hi9RhScTBU
(last visited July 1, 2026).
12
This description emphasizes their versatility and uses in many technical and industrial settings,
which is inconsistent with a sole or principal use only with certain machines—the machines of
headings 8456 to 8465. Moreover, in describing their potential uses, NK states that their cam
levers are used in part in “medical and rehabilitation technology.” Id. This statement is a specific
description identifying a principal use of the cam levers that appears to fall outside of use with
the machines of headings 8456 to 8465. Instead, it appears to indicate that they are used in part
with the instruments of headings under Chapter 90, HTSUS: “Optical, photographic,
cinematographic, measuring, checking, precision, medical or surgical instruments and apparatus;
parts and accessories thereof.” Therefore, the evidence of record does not demonstrate that the
subject cam levers are used solely or principally with the machines of headings 8456 to 8465,
and thus, they cannot be classified under heading 8466, HTSUS.
E. Classification Under Headings 7326 and 7616, HTSUS, as Other Articles of
Aluminum and Steel
In NY N361167, supra, the subject cam levers were classified under headings 7326 and
7616, HTSUS, as other articles of iron or steel and other articles of aluminum. Note 2 to Section
XV, HTSUS, provides, in pertinent part, that “subject to the preceding paragraph and to note 1 to
chapter 83, the articles of chapter 82 or 83 are excluded from chapters 72 to 76 and 78 to 81.”
Furthermore, the General EN to Section XV, HTSUS, states in pertinent part:
Each of the Chapters 72 to 76 and 78 to 81 covers particular unwrought base
metals and products of those metals such as bars, rods, wire or sheets, as well as
articles thereof, except certain specified articles of base metal which, without
regard to the nature of the constituent metal, are classified in Chapter 82 or 83,
these Chapters being limited to the specified articles.
Therefore, because the subject cam levers are classifiable in Chapter 82 and specifically
under heading 8205, HTSUS, they must be so classified.
HOLDING:
By application of GRIs 1 and 6, cam lever models K0005.25011A3, K0005.2501110X40,
K0006.15011A2X20, and K2120.15011A2 are classified in heading 8205, HTSUS, specifically
in subheading 8205.59.7000, HTSUSA, which provides for “Handtools (including glass cutters)
not elsewhere specified or included; blow torches and similar self-contained torches; vises,
clamps and the like, other than accessories for and parts of machine tools or water-jet cutting
machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks;
base metal parts thereof: Other handtools (including glass cutters) and parts thereof: Other:
Other: Of aluminum.” The 2026 column one general rate of duty for subheading 8205.59.7000,
HTSUSA, is 1.5 cents per kilogram plus 3.5%.
By application of GRIs 1 and 6, cam lever model K0647.15120A2X20 is classified in
heading 8205, HTSUS, specifically in subheading 8205.59.5560, HTSUSA, which provides for
“Handtools (including glass cutters) not elsewhere specified or included; blow torches and
13
similar self-contained torches; vises, clamps and the like, other than accessories for and parts of
machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated
grinding wheels with frameworks; base metal parts thereof: Other handtools (including glass
cutters) and parts thereof: Other: Other: Of iron or steel: Other: Other (including parts).” The
2026 column one general rate of duty for subheading 8205.59.5560, HTSUSA, is 5.3%.
This ruling does not address the applicability of any additional duties that may apply to
the goods discussed herein. Likewise, duty rates are provided for your convenience and are
subject to change. The text of the most recent HTSUS and the accompanying duty rates are
provided at www.usitc.gov.
EFFECT ON OTHER RULINGS:
NY N361167, dated May 15, 2026, is hereby REVOKED.
This revocation is not subject to the notice and comment provisions of 19 U.S.C. §
1625(c) because NY N361167 was in effect for less than 60 days. See 19 C.F.R. § 177.12(b).
Sincerely,
Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
14