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