CLA-2-82:OT:RR:NC:N1:118
Tianqi Jiang
Burlington Coat Factory Warehouse Corporation
1830 Route 130 North
Burlington, NJ 08016
RE: The tariff classification of a hex key set from China
Dear Ms. Jiang:
In your letter dated September 24, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as a 30 Piece Hex Key Set, style name EU-HKS030. The
set includes various sizes of metric and SAE hex keys made of chromium–vanadium heat-treated steel. The
pictures you provided indicate that the set will be imported packaged for retail sale in a specially fitted case.
Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in
accordance with the General Rules of Interpretation (GRIs). GRI 1 states in part that for legal purposes,
classification shall be determined according to the terms of the headings and any relative section or chapter
notes. The various sizes of hex keys are all classified within the same subheading. Therefore, the 30 Piece
Hex Key Set will be classified in accordance with GRI 1. GRI 5 of the HTSUS states that camera cases,
musical instrument cases, gun cases, drawing instrument cases, necklace cases and similar containers,
specially shaped or fitted to contain a specific article or set of articles, suitable for long-term use and entered
with the articles for which they are intended, shall be classified with such articles when of a kind normally
sold therewith. The case for the tools meets the requirements of GRI 5(a) and therefore does not need to be
classified separately.
The applicable subheading for the 30 Piece Hex Key Set, style name EU-HKS030, will be 8204.11.0060,
HTSUS, which provides for hand-operated spanners and wrenches (including torque meter wrenches but not
including tap wrenches); socket wrenches, with or without handles, drives or extensions; base metal parts
thereof: hand-operated spanners and wrenches, and parts thereof: nonadjustable, and parts thereof: other
(including parts). The general rate of duty will be 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 903.01.23, 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 8204.11.0060, 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 8204.11.0060, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8203.20.6030, 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 8204.11.0060, 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
(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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division