CLA-2-84:OT:RR:NC:N1:164
Tianqi Jiang
Burlington Coat Factory Warehouse Corporation
1830 Route 130 North
Burlington, NJ 08016
RE: The tariff classification of a tool set from China
Dear Tianqi Jiang:
In your letter dated September 22, 2025, you requested a tariff classification ruling on a tool set from China.
You submitted pictures and product information with your request.
The item under consideration is described as a 103-piece mechanics tool kit which will be imported in a
molded case ready for retail sale. The tool set consists of the following:
1 - 3/8-inch drive ratchet handle
1 - 3/8-inch drive extension bar
1 - 1/4-inch driver bit handle
1 - 6-inch adjustable wrench
1 - 6-inch long nose pliers
1 - 7-ounce claw hammer
6 - Precision screwdrivers
1 - Socket adapter
33 - Screwdriver bits
22 - Hex keys
15 - Metric drive sockets
18 - SAE drive sockets
1 - Measuring tape
1 - Pack of assorted fasteners
Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in
accordance with the General Rules of Interpretation (GRIs). GRI 1, HTSUS, states in part that for legal
purposes, classification shall be determined according to the terms of the headings, any relative section or
chapter notes and, unless otherwise required, according to the remaining GRIs taken in order. Goods that are,
prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. The instant
tool set consists of at least two different articles that are, prima facie, classifiable in different headings. It
consists of articles put up together to carry out a specific activity (i.e., mechanical repair and maintenance).
Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the
set in question is within the term “goods put up in sets for retail sale.”
GRI 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to GRI
3(a), are to be classified as if they consisted of the component which gives them their essential character.
Inasmuch as no essential character can be determined, GRI 3(b) does not apply. GRI 3(c) states that, if
neither GRI 3(a) nor GRI 3(b) applies, merchandise shall be classified in the heading which occurs last in
numerical order among those equally meriting consideration.
In this case, no essential character can be determined due to the diverse nature of the items. As a result, GRI
3(b) does not apply and we must consider classification under GRI 3(c). It is the opinion of this office that
the items equally meriting consideration are the ratchet handle, extension bar, driver bit handle, adjustable
wrench, pliers, hammer, screwdrivers, socket adapter, screwdriver bits, hex keys, and sockets. Pursuant to
GRI 3(c), the items which occur last in numerical order among those equally meriting consideration are the
tool holders (e.g., ratchet handle, driver bit handle, extension bar, socket adapter) which are provided for in
heading 8466, HTSUS. Accordingly, the entire set will be classified in heading 8466.
The applicable subheading for the 103-piece tool set 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division