CLA-2-68:OT:RR:NC:N1:128
Mr. Martin Burkhard
Burkhard Baumsteigtechnik GmbH & Co. KG
Im Dornbusch 2
Heidelberg 69123
Germany
RE: The tariff classification of carbon fiber climbing spurs from Germany.
Dear Mr. Burkhard:
In your letter dated October 6, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as Distel Carbon Fiber 3.1. A sample was submitted with
your ruling request and will be retained by this office.
From the information provided, the Distel Carbon Fiber 3.1 are climbing spurs designed for use by
professional arborists to climb trees for removal, and by line mechanics to climb utility poles for
maintenance. The spurs are sold in pairs, and consist of a padded polypropylene plastic leg shell, a J-shaped
carbon fiber shank/stirrup, and a steel gaff, as well as hook-and-loop straps and buckles.
When worn, the leg shell is designed to wrap around the user’s calf, while the shank runs along the inner leg,
positioning the stirrup beneath the foot. The steel gaff is attached to the shank near the stirrup. The spurs are
held in place by the straps and buckles. While climbing, the gaff is designed to pierce the tree trunk or utility
pole, providing traction and stability. The leg shell and shank distribute the user’s weight, while the
rubber-soled stirrup allows for easier grip of tree branches or other footholds.
The Distel Carbon Fiber 3.1 climbing spurs are constructed of different materials that are classifiable in
different headings. The classification of merchandise under the Harmonized Tariff Schedule of the United
States (HTSUS) is governed by the General Rules of Interpretation (GRIs), taken in order. GRI 1 requires
that classification be determined according to the terms of the headings and any relative section or chapter
notes. In the event that goods cannot be classified solely on the basis of GRI 1, and if the heading and legal
notes do not otherwise require the remaining GRIs will be applied, in the order of their appearance. GRI 3(b)
provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be
classified as if they consisted of the material or component which gives them their essential character. The
carbon fiber shank provides the essential character of the climbing spur.
The applicable subheading for the Diestel Carbon Fiber 3.1 climbing spurs will be 6815.13.0000, HTSUS,
which provides for “Articles of stone or of other mineral substances (including carbon fibers, articles of
carbon fibers and articles of peat) not elsewhere specified or included: Carbon fibers; articles of carbon
fibers for non-electrical uses…Other articles of carbon fibers.” The general rate of duty will be Free.
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 the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 6815.13.0000, 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 Nicole Sullivan at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division