CLA-2-82:OT:RR:NC:N1: 118
Pamela Waddell
Central Purchasing LLC dba Harbor Freight Tools
26677 Agoura Road Calabasas, CA 91302
RE: The tariff classification of Hex Key Driver Sets from China
Dear Ms. Waddell:
In your letter dated February 13, 2023, you requested a tariff classification ruling on four different T-handle hex key driver sets.
The first item, SKU 62172, is a 10-piece Metric T-Handle Hex Key Set. It includes ten t-shaped handled hex key drivers designed for turning hex head screws. The set is imported with a fitted display stand of carbon steel to keep them organized. Each hex key driver is made of chrome vanadium steel with a black oxide finish. The shaft is straight, and the t-handles are made of plastic for a firm grip and easy turning on the main axis like a screwdriver. The sizes in the set are metric and include 2 mm, 2.5 mm, 3mm, 4 mm, 4.5mm, 5 mm, 5.5 mm, 6 mm, 8 mm, and 10 mm.
The second item, SKU 58772, is an 8-piece Professional High Torque T-Handle Torx® Key set. Each of the eight Torx® key drivers includes a short and long blade star bit designed for turning star bit (Torx®) head screws. The set is imported with a fitted polystyrene storage tray to keep the tools organized. Each star bit driver is made of S2 alloy steel with a black oxide finish and the handle has an ergonomic grip molded from Polypropylene and TPR. The offset handle encases a short blade star bit in addition to the long blade star bit like the t-handle hex key drivers. Both shafts are straight with an ergonomic grip allowing for easy turning on the main axis like a screwdriver. Each handle has a hanging hole for easy storage and is color-coded to identify the star bit (Torx®) style which includes T10, T15, T20, T25, T27, T30, T40, and T45.
The third item, SKU 58698, is a Metric 8-piece Professional High Torque T-Handle Hex Key set. Each of the eight hex key drivers includes a short and long blade featuring a hex key tip designed for turning hex head screws. The set is imported with a fitted polystyrene storage tray to keep the tools organized. Each hex key driver is made of S2 alloy steel with a black oxide finish and the handle has an ergonomic grip molded from Polypropylene and TPR. The offset handle encases a short blade hex key bit in addition to the long blade hex key bit like the single t-handle hex key drivers. Both shafts are straight with an ergonomic grip allowing for easy turning on the main axis like a screwdriver. Each handle has a hanging hole for easy storage and is color-coded to identify it as metric and includes sizes 2 mm, 2.5 mm, 3 mm, 4 mm, 5 mm, 6 mm, 8 mm, and 10 mm.
The fourth item, SKU 63167, is an SAE & Metric T-Handle Ball End Hex Key Set of eighteen pieces. The set consists of nine SAE and nine metric off-set T-handle hex key drivers. Each of the hex key drivers includes a long shaft featuring a ball point hex key and a short shaft featuring a standard hex key, both designed for turning hex head screws. The set is imported with a fitted display stand of carbon steel to keep the tools organized. Each hex key driver is made of chrome vanadium steel with a black oxide finish and the handle has an ergonomic grip molded from PVC. Both shafts are straight with an ergonomic grip allowing for easy turning on the main axis like a screwdriver. The set includes the following SAE sizes: 1/16”, 5/64”, 3/32”, 1/8”, 5/32”, 3/16”, 7/32”, 5/16”, 3/8”, and the following metric sizes: 1.5 mm, 2 mm, 2.5 mm, 3 mm, 4 mm, 5 mm, 6 mm, 8 mm, and 10 mm.
The applicable subheading for the four T-handle hex key driver sets (SKU 62172, SKU 58772, SKU 58698, and SKU 63167) will be 8205.40.0000, Harmonized Tariff Schedule of the United States (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 or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: screwdrivers, and parts thereof. The general rate of duty will be 6.2% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8205.40.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8205.40.0000, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.
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 https://hts.usitc.gov/current
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Anthony Grossi at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division