CLA-2-76:OT:RR:NC:N1:164
Martin Francis
DMM International
Llanberis, Gwynedd LL55 4EL
United Kingdom
RE: The tariff classification of carabiners from the United Kingdom
Dear Mr. Francis:
In your letter dated December 17, 2025, you requested a tariff classification ruling regarding carabiners from
the United Kingdom. You submitted technical information with the request.
The three carabiner models under consideration are described as locking carabiners which are designed and
marketed primarily for mountaineering and recreational climbing activities. You state that the locking gate
design prevents accidental opening during use, prevents gate flutter under load, and enhances the ease of
clipping and unclipping ropes, slings, and other equipment. The “Screwgate” model incorporates a manual
screw-locking gate mechanism. The “Kwiklock” and “Locksafe” models incorporate a manual locking gate.
All models require deliberate user action to lock and unlock the gate to prevent unintended opening. In your
request, you clarify that the carabiners are not motorized, do not contain electronic components, and have no
moving parts beyond the gate and screw-locking sleeve
Depending on the model and product variant, the carabiners consist of several metal and plastic components.
As you described, the predominant material is aluminum. The carabiners will be imported in a variety of
sizes, weights, strength ratings, and colors.
You have requested classification of the subject good under heading 9506, Harmonized Tariff Schedule of
the United States (HTSUS), which provides, in relevant part, for “articles and equipment for… other sports.”
However, we find that this item has a variety of other applications. Internet research indicates that carabiners
designed and marketed as suitable for sports such as mountaineering are used for a number of other purposes
unrelated to sports. Moreover, the instructions submitted in connection with the subject good reference its
value for individuals “working at height” which suggests utility in a broad range of activities or pursuits. As a
result, classification in heading 9506, HTSUS, is precluded.
Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation
(GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the
headings and any relative section or chapter notes. Since no one heading in the tariff schedule covers the
components of the carabiners in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b)
provides that mixtures, composite goods consisting of different materials or made up of different
components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or
component which gives them their essential character.
As the carabiners are composite goods, we must apply rule GRI 3(b), which provides that composite goods
are to be classified according to the component that gives the goods their essential character. Explanatory
Note (EN) VIII to GRI 3(b) explains that “the factor which determines essential character will vary as
between different kinds of goods. It may, for example, be determined by the nature of the material or
component, its bulk, quantity, weight or the use of the goods.” We must determine which component imparts
the essential character to the carabiners in question. In our opinion, the role of the constituent materials or
components in relation to the use of the good is the portion that imparts the essential character. In this case,
the metal components impart the essential character.
Section XV, Note 7 of the HTSUS states that the classification of composite articles of base metal containing
two or more base metals are to be treated as articles of the base metal that predominates by weight over each
of the other metals. Based on the information provided to our office, the predominant metal by weight is a
luminum. Therefore, the articles in question are classifiable as articles of aluminum.
Accordingly, the applicable subheading for the Screwgate, Kwiklock, and Locksafe carabiners will be
7616.99.5190, HTSUS, which provides for “Other articles of aluminum: Other: Other: Other: Other: Other:
Other.” The general rate of duty will be 2.5 percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division