CLA-2-84:OT:RR:NC:N1:164
Cynthia DelCorto
DSV Air & Sea Inc.
395 Oyster Pt. Blvd., Suite 420
South San Francisco, CA 94080
RE: The tariff classification of a cabinet hardware jig from China
Dear Ms. DelCorto:
In your letter dated June 4, 2025, you requested a tariff classification ruling regarding a cabinet hardware jig
from China on behalf of your client, Kreg Tool Company. Product information was submitted with your
request.
The item under consideration is described as a cabinet hardware jig to assist a user in accurately drilling holes
with proper spacing and alignment when installing pulls and knobs on cabinetry and drawers. The
predominantly aluminum article features laser-etched measuring scales and two adjustable guide blocks with
hardened steel drill guides. The ability to precisely adjust the guide block assemblies and maintain their
position provides a predictable and repeatable setup for accurate drilling. After the components are positioned
as desired, a user holds the jig against a cabinet or drawer and pushes a drill bit extending from a handheld
drill through the opening of the steel drill guides and into the surface of the cabinet or drawer. Based on the
submitted information, the cabinet hardware jig is specifically designed for use with a handheld drill.
In your letter, you suggested classifying the Cabinet Hardware Jig within subheading 8205.51.6000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “other” household tools of
aluminum. We disagree. Hand tools included in heading 8205, HTSUS, are not defined in the HTSUS or the
Explanatory Notes (ENs). In Headquarters ruling letter (HQ) 966118, dated September 11, 2003, Customs
noted that the courts have defined a hand tool as “any tool which is held and operated by the unaided hands;
e.g., a chisel, plane or saw.” See Western Oilfields Supply Co. v. United States, 296 F. Supp. 330, 62 Cust.
Ct. 182 (1969); Hollywood Accessories, Division of Allen Electronics & Equipment Co. v. United States,
282 F. Supp. 499, 60 Cust. Ct. 360 (1968); F.B. Vandegrift & Co., Inc. v. United States, 65 Cust. Ct. 260
(1970).
Similarly, Note 1 to Chapter 82, HTSUS, states that, with certain exceptions, “this chapter covers only
articles with a blade, working edge, working surface or other working part of: (a) Base metal….” The court in
Continental Arms Corp.; Gehrig, Hoban & Co., Inc. v. United States, 65 Cust. Ct. 80, 82 (1970), defined a
“working part” as the part of a hand tool “which performs work on an external object… that part of the tool
which does work in relation to a workpiece or object external to the tool.”
The cabinet hardware jig is used as a template that enables a user to drill straight and accurately positioned
screw holes for pulls and knobs on drawers and cabinets. As such, it does not have a “working part” as
defined above and within the meaning of Note 1 to Chapter 82. Furthermore, the cabinet hardware jig does
not meet the definition of a hand tool as discussed in HQ 966118 and the court cases cited above.
Accordingly, we find that the Cabinet Hardware Jig is not classifiable as a hand tool in heading 8205,
HTSUS.
Alternatively, you propose classification in subheading 8466.10.0175, HTSUS. We agree. The ENs to
heading 8466 state, in part, “Tool holders which hold, guide or operate the working tool and which permit the
interchange of such tool-pieces.” Furthermore, the ENs clarify “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
8205 or 8467….” Since the cabinet hardware jig at issue is specially designed to guide the drill bit of a
handheld drill during use, classification in heading 8466 is appropriate.
The applicable subheading for the cabinet hardware jig will be 8466.10.0175, HTSUS, 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: Tool holders and self-opening dieheads:
Other. The general rate of duty will be 3.9 percent ad valorem.
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 8466.10.0175, 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
8466.10.0175, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8466.10.0175, 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. 01,
in addition to subheading 8466.10.0175, 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, including
information on exclusions and their effective dates, 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/programs-administration/trade-remedies, respectively.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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/.
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
(C.F.R.), 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 C.F.R. 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 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 Paul Taylor at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division