CLA-2-82:OT:RR:NC:N1:118
Daniel Morgan
Columbia Products
1622 Browning
Irvine, CA 92606
RE: The tariff classification of scoops from China
Dear Mr. Morgan:
In your letter dated July 9, 2025, you requested a tariff classification ruling.
The items under consideration are identified as industrial scoops and pharma scoops. Both are made of
18-gauge type 304 stainless steel. The bowls of the scoops are concave in shape and have welded handles
attached. You have stated that the industrial scoops are used in agriculture, horticulture and food processing
applications to move materials such as dry fertilizer, grain, rice or other food products. The pharma scoops
are primarily used in the pharmaceutical industry to transfer powders, liquids or pills from one location to
another. Both scoops will be imported in various lengths and sizes that can hold quantities ranging from 8
ounces to 160 ounces.
You suggested classifying the scoops within subheading 8201.10.0000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for spades and shovels. We disagree. A shovel is a tool with a long
handle and a wide, flat blade that is used for digging or lifting heavy material such as earth, snow, or coal. A
spade is a tool with a sharp-edged, typically rectangular, metal blade and a long handle that is used for
digging or cutting earth, sand, turf, etc. The scoops under consideration do not meet these definitions,
therefore your proposed classification is incorrect.
The applicable subheading for the industrial scoops and pharma scoops will be 8205.59.5560, 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: other handtools (including glass cutters) and parts thereof: other: other:
of iron or steel: other: other (including parts). The general rate of duty will be 5.3 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 8205.59.5560, 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
8205.59.5560, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8205.59.5560, 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 8205.59.5560, HTSUS, listed above.
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
(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 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division