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 hole saw set from China
Dear Ms. Jiang:
In your letter dated October 21, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as an 11 Piece Hole Saw Set, style name EU-HSS011. The
set includes eight steel hole saws in 3/4", 7/8", 1-1/8", 1-1/4", 1-1/2", 1-3/4", 2", and 2-1/2" sizes, two arbors,
and one hex key. The hole saws are used with power drills to cut circular holes in various materials. Each
arbor facilitates the connection between a hole saw and a drill. The hex key is used to turn hexagonal shaped
bolts and screws on the arbor when connecting a hole saw to a drill. The pictures you provided indicate that
the articles will be imported packaged for retail sale.
The 11 Piece Hole Saw Set is imported in a single retail package that contains articles that are classifiable
under different headings of the tariff. The Explanatory Notes represent the official interpretation of the
Harmonized Tariff Schedule (HTS) at the international level. General Rule of Interpretation (GRI) 3 applies
when goods are put up for sale collectively and are classifiable under two or more headings of the tariff. GRI
3(b) covers goods put up in sets for retail sale. Explanatory Note X to GRI 3(b) defines “goods put up in sets
for retail sale.” Such goods: (a) consist of at least two different articles that are classifiable in different
headings, (b) consist of products put up together to meet a particular need or carry out a specific activity, and
(c) are put up in a manner suitable for sale directly to users without repacking. The subject articles in the 11
Piece Hole Saw Set, in our opinion, meet the criteria for sets as the terms are defined in the cited Explanatory
Note. Therefore, for the purposes of the HTS, the merchandise constitutes a set. Having determined that the
items constitute a set for tariff classification purposes, we must decide the essential character. According to
the Explanatory Note to GRI 3(b), essential character may be determined by the nature of the material or
component, its bulk, quantity, weight or value, or by the role of the constituent material in relation to the use
of the goods. In this case, we find that the eight hole saws impart the essential character to set.
The applicable subheading for the 11 Piece Hole Saw Set, style name EU-HSS011, will be 8202.99.0000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for handsaws, and metal parts
thereof; blades for saws of all kinds (including slitting, slotting or toothless saw blades), and base metal parts
thereof: other saw blades, and parts thereof: other (including parts). The general rate of duty will be free.
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 8202.99.0000, 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 8202.99.0000, 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 8202.99.0000, 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 Notes cited above and the applicable Chapter 99 subheadings. 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division