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 spade bit 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 a 7 Piece Spade Bit Set, style name EU-DBS007. The
set includes seven spade drill bits in 3/8", 1/2", 5/8", 3/4", 7/8", 1", and 1-1/4" sizes. The bits are made of
steel and are used with a power drill to drill large diameter holes in wood. You have stated that the cutting
parts of each bit do not contain by weight over 0.2 percent chromium, molybdenum, or tungsten, or over 0.1
percent vanadium. The pictures you provided indicate that the set of bits will be imported packaged for retail
sale in a specially fitted case.
You suggested that the 7 Piece Spade Bit Set should be classified as a set in accordance with General Rule of
Interpretation (GRI) 3 of the Harmonized Tariff Schedule of the United States (HTSUS). We disagree. 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 spade bits are all classified within the
same subheading. Therefore, the 7 Piece Spade Bit 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 bits meets the requirements of GRI
5(a) and therefore does not need to be classified separately.
The applicable subheading for the 7 Piece Spade Bit Set, style name EU-DBS007, will be 8207.50.6000,
HTSUS, which provides for interchangeable tools for handtools, whether or not power operated or for
machine tools …: tools for drilling, other than rock drilling, and parts thereof: other: not suitable for cutting
metal, and parts thereof: for handtools, and parts thereof. The general rate of duty will be 5.2 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 8207.50.6000, 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 8207.50.6000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8207.50.6000, 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 8207.50.6000, 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