Ms. Debbie Brule
Jacobson Global Logistics Inc.
18209 80th Ave So, Suite A
Kent, WA 98032

RE: The tariff classification of a Universal Chain Saw Tool from China.

Dear Ms. Brule:

In your letter dated April 23, 2013, on behalf of BAC Industries, Inc., you requested a tariff classification ruling. The sample you have submitted is being returned as requested.

The submitted sample, item number TMW-22, is described as a Universal Chain Saw multi-tool. This hand-held tool is made of steel and consists of the following fold-out tools: 4 mm Allen Key Small flat head screwdriver Large flat head screwdriver 5 mm star head screwdriver Two double end sockets – sizes 13 mm 16 mm, 17 mm and 19 mm Three hexangular wrenches – sizes 10 mm, 13 mm, 17 mm Bar cleaner – removes sawdust from the chain bar Wheel and stone gauge – used as a guide to determine which size file is required to sharpen the chain. The item is imported packaged in a blister display pack along with a fitted textile pouch.

You propose classification in accordance with General Rule of Interpretation (GRI) 3(c) under 9017.30.8000, Harmonized Tariff Schedule of the United States (HTSUS), due to the wheel and stone gauge. GRI 3(c) states that when the essential character of a composite good cannot be determined, classification is based on the heading that occurs last in numerical order among those which equally merit consideration. It is the opinion of this office that the wheel and stone gauge does not merit equal consideration in comparison to the other fold-out tools. Therefore, the two headings under consideration are heading 8204, HTSUS, which provides for the Allen key, sockets and wrenches; and heading 8205, HTSUS, which provides for the screwdrivers and bar cleaner. As there is no one principal function among these tools, the Universal Chain Saw Tool is classifiable under heading 8205, HTSUS, in accordance with GRI 3 (c). The applicable subheading for the Universal Chain Saw Tool, item number TMW-22, will be 8205.59.5510, HTSUS, 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; 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: edged handtools: other. The rate of duty will be 5.3% ad valorem.

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 on World Wide Web at

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Anthony Grossi at (646) 733-3021.


Thomas J. Russo
National Commodity Specialist Division