CLA-2-84:OT:RR:NC:N1:104
Ms. Jessica Woltering
C.H. Robinson
14800 Charlson Rd.
Suite 400
Eden Prairie, MN 55347
RE: The tariff classification of a drill guide from China
Dear Ms. Woltering:
In your letter dated June 13, 2017 on behalf of Kreg Tool Company, you requested a tariff classification ruling.
The one piece drill guide, Style #NK8310, is made of hardened steel and is approximately 95mm in length and 19mm in diameter with a 12mm diameter hole to fit a drill bit (imported separately). It is designed to be used with the Pocket-Hole Machine, Item #DB210. The drill guide’s primary function is said to be to guide a drill bit into a piece of wood in order to drill a pocket hole. The drill guide and drill bit are placed into the base of the Pocket-Hole Machine. When the user pushes down on the machine’s handle, a 12mm diameter pocket hole is drilled into a piece of wood as the drill bit is pushed through the drill guide into the wood. While the Pocket-Hole Machine is sold with a drill guide already attached, these drill guides are being imported separately as replacement parts.
In your letter, you propose classifying the drill guide, Style #NK8310, under subheading 8466.20.8065, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for machine tools; tool holders for any type of tool for working in the hand: Work holders: Other: Other work holders: Other”. The submitted “Owner’s Manual” contains a description of the relationship between the drill bit and the drill guide. The drill bit is inserted into the drill guide. This description shows how the drill guide is used to both guide the tool, i.e., the drill bit, and permit the interchange of such drill bits. The drill guide is not being used to hold the workpieces, i.e., the wood that is being processed. As such, classification of the drill guide as a work holder in subheading 8466.20.8065, HTSUS, would not be appropriate.
The applicable subheading for the drill guide, Style #NK8310, will be 8466.10.0130, HTSUS, which provides for “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for machine tools; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Holders for replaceable cutting or drill inserts”. The rate of duty will be 3.9 percent ad valorem.
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 on World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Patricia O’Donnell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division