CLA-2-82:OT:RR:NC:N4:415
Gregory D. Schob
Sparrow Knife Co.
1806 Shelby Lane
Ocean Springs, MS 39564
RE: The tariff classification of pocket knives from China.
Dear Mr. Schob:
In your letter dated May 5, 2025, you requested a tariff classification ruling.
The products under consideration are steel pocket knives that are described in your submission as small,
handheld folding knives about three inches long when folded, about six inches long when deployed, and
weigh about five ounces each.
The applicable subheading for steel pocket knives will be 8211.93.0035, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “[k]nives with cutting blades, serrated or not (including pruning
knives), other than knives of heading 8208, and blades and other base metal parts thereof: [o]ther: [k]nives
having other than fixed blades: [p]en knives, pocket knives and other knives which have folding blades.”
The column one, general rate of duty is 3 cents each plus 5.4 percent ad valorem.
You inquired whether the Section 232 additional duties on certain derivative steel products applies to these
pocket knives. Articles of subheading 8211.93.0035, HTSUS, are not among those listed in Annex 1 to
Presidential Proclamation 10896.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 8211.93.0035, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to subheading
8211.93.0035, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8211.93.0035, 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 8211.93.0035, 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.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division