CLA-2-82:OT:RR:NC:N1:118

Tyler Keith
Flexport Customs, LLC
100 California Street, Floor 5
San Francisco, CA 94111

RE: The tariff classification of knife sharpeners from China

Dear Mr. Keith:

In your letter dated January 27, 2026, you requested a tariff classification ruling on behalf of your client, Acme United Corporation. Samples of the items were submitted for review and will retained by our office.

The items under consideration are four household knife sharpeners. The knife sharpeners are identified and described as follows:

The EdgeSharp DiamondBench Pro Sharpener (SKU 20248) is a 3-stage, pull-through, manual knife sharpener. It includes a coarse tungsten steel slot for repairing dull or damaged blades, a diamond (diamond affixed to carbon steel) slot to add a fine edge, an extra-fine ceramic slot to attain a razor-sharp edge, and a pull-through integrated ceramic shear sharpener for kitchen scissors. The base is made primarily of acrylonitrile butadiene styrene plastic (ABS), which includes an overlay of stainless steel and a thermoplastic rubber (TPR) non-slip bottom that provides a stable sharpening platform. The large ergonomic ABS plastic handle features a textured grip for comfort and control when handling.

The EdgeSharp PocketSharp Sharpener (SKU 20243) is a compact, lightweight diamond sharpener for chef, kitchen, and slicing knives. It incorporates a coarse tungsten steel slot on one side for repairing damaged or dull blade edges, and a ceramic slot that produces a fine edge. The side grips are made of TPR and the interior sharpener base of ABS plastic. A removable iron beaded chain allows the sharpener to be hung for easy reach.

The EdgeSharp SharpAdjust Sharpener (SKU 20246) is a standing sharpener with an adjustable pull-through tungsten steel V-groove that accommodates paring knives, chef’s knives, cleavers, and other blades. For customizable precision, users can choose from six preset angles via a dial mechanism. The base of the sharpener is made of ABS plastic, TPR, polyoxymethylene, stainless steel, and carbon steel. The Pioneer Woman Knife Sharpener (SKU 20276) is a 4-stage sharpener with eight angles that can be adjusted via a dial at the top of the handle. It includes a tungsten steel coarse sharpening slot, a diamond (diamond affixed to iron) fine sharpening slot, a ceramic super-fine sharpening slot, and a diamond affixed to iron sharpener. The sharpener’s adjustable angle settings make it versatile for use with a wide range of kitchen knives. The non-slip handle and non-slip feet provide stability and safety during use. The outer part of the handle is made of ABS plastic and the interior of TPR. The non-slip feet are made of silicone rubber.

Each knife sharpener is considered to be a composite good within the meaning of General Rule of Interpretation (GRI) 3. Goods classifiable under GRI 3(b) shall be classified as if they consisted of the material or a component which gives them their essential character. The Explanatory Note to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3 (b) (VIII), states that the factors which determine essential character will vary between different kinds of goods. It may, for example, be determined by the nature of materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. Our office examined the samples you submitted, along with the value and percentage breakouts of the material composition of each sharpener. It is our opinion that the steel or iron portion of the sharpeners impart the essential character of each sharpener.

The applicable subheading for the EdgeSharp DiamondBench Pro Sharpener (SKU 20248), EdgeSharp PocketSharp Sharpener (SKU 20243), EdgeSharp SharpAdjust Sharpener (SKU 20246), and Pioneer Woman Knife Sharpener (SKU 20276) will be 8205.51.3030, HTSUS, which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: household tools, and parts thereof: of iron or steel: other (including parts): kitchen and table implements. The general rate of duty will be 3.7% 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 (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