CLA-2-82:OT:RR:NC:N4:415
Kim Benedetto
Seasons USA, Inc.
2041 Genesee Street
Utica, NY 13501
RE: The tariff classification of two pumpkin carving sets from Indonesia.
Dear Ms. Benedetto:
In your letter dated April 4, 2025, you requested a tariff classification ruling on behalf of your client, Seasons
HK, Ltd.
Images were submitted in lieu of samples.
There are two products under consideration.
The first set is described as the “Pumpkin Carving Kit 5pcs,” style number J00015. It consists of three
carving knives, listed as a detailer, a miter carver, and a small carver. They all feature blades made of iron
and handles of acrylonitrile butadiene styrene (ABS) plastic. Also included in this kit is a poker tool and
scoop both made wholly of ABS plastic.
The second set is described as the “Pumpkin Carving Kit 4pcs,” style number J00016. It consists of two
carving knives, listed as a carver and a detailer. They feature blades made of iron and handles of ABS
plastic. Also included in this kit is a tracer tool with a working surface of iron and a handle of ABS plastic
and scoop made wholly of ABS plastic.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the Harmonized System at the international level. While not legally binding nor dispositive,
the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of
the proper interpretation of these headings. For these two sets, we look to the note for subheading 8211.10,
that states “the scope of subheading 8211.10 is limited to sets of different knives or sets of assorted articles,
in which the knives predominate in number over the other articles.”
The five-piece set consists of three knives and two other articles. As such, we find it meets this note, and it
would be appropriately classified under subheading 8211.10. In contrast, the four-piece set has two knives
and two other articles, so the knives would not predominate over the other articles. Therefore, it will be
classified in accordance with General Rule of Interpretation 3(b) by the knives as they would impart the
essential character to the set.
The applicable subheading for the “Pumpkin Carving Kit 5pcs,” style number J00015, will be 8211.10.0000,
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: [s]ets of assorted articles.”
This set will be dutiable at the rate of duty applicable to that article in the set subject to the highest rate of
duty. The detailer knife provides the highest rate when compared to the other equivalent ad valorem rates.
As the handle is made from plastic, this knife is classified in subheading 8211.92.2000, HTSUS, which is
dutiable at .8 cents each plus 4.6 percent.
The complete tariff classification for the “Pumpkin Carving Kit 5pcs,” style number J00015, will be
8211.10.0000 / 8211.92.9030.
The applicable subheading for the “Pumpkin Carving Kit 4pcs,” style number J00016, will be 8211.92.2000,
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: [o]ther knives having
fixed blades: [w]ith rubber or plastic handles: [k]itchen and butcher knives.” The column one, general rate of
duty is 0.8 cents each plus 4.6 percent ad valorem
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. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
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
subheadings 8211.10.0000 / 8211.92.9030 and 8211.92.9030, HTSUS, listed above.
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, contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division