CLA-2-82:OT:RR:NC:N4:415
Kathy Trotta
Conair, LLC
1 Cummings Point Road
Stamford, CT 06902
RE: The tariff classification of three knife sets from China.
Dear Ms. Trotta:
In your letter dated July 9, 2024, you requested a tariff classification ruling.
Images were submitted in lieu of samples.
There are three products under consideration.
The first set is described as 7 Pc Cutlery Block Set Stainless Steel Hollow Handles, item number C77SS-7P2. It contains the following items: an eight-inch chef knife, an eight-inch slicing knife, a seven-inch santoku knife, a 5.5-inch serrated utility knife, a 3.5-inch paring knife, kitchen shears, and an Acacia wood block with a built-in sharpener. We note the blades and handles are both made from stainless-steel.
The second set is described as 7 Pc knife Block Set Stainless Steel Hollow Handle, item number C77SS-7PBS. The contents of this knife set are the same as the one above with the only difference being the handles of the knives have a different design/shape.
The third set is described as T/R 15 PC Sharp Block Set, item number C77TRN-15SH. It contains the following items: an eight-inch chef knife, an eight-inch slicing knife, an eight-inch bread knife, a seven-inch santoku knife, a five-inch serrated utility knife, a 3.5-inch paring knife, six 4.5-inch steak knives, and a Rubberwood block with a built-in sharpener and honer. We note that the blades are stainless-steel, and the handles are made from acrylonitrile butadiene styrene (ABS) plastic, except for the butts and the handle fasteners which are also stainless-steel.
The applicable subheading for these three sets, item numbers C77SS-7P2, C77SS-7PBS, and C77TRN-15SH, will be 8211.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for [k]nives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof: [s]ets of assorted articles.
These sets will be dutiable at the rate of duty applicable to that article in the set subject to the highest rate of duty. The 3.5-inch paring knife provides the highest rate for all of the sets when combined with the additional Section 301 7.5 percent duty rate, when compared to the other equivalent ad valorem rates. As the first two sets have stainless-steel handles, those knives will be classified in subheading 8211.92.9030, HTSUS, which is dutiable at .4 cents each plus 6.1 percent. The handles of the third set are predominately made from plastic, so the paring knife is classified in subheading 8211.92.2000, HTSUS, which is dutiable at .8 cents each plus 4.6 percent.
The complete tariff classification for the first two sets, item numbers C77SS-7P2 and C77SS-7PBS, will be 8211.10.0000 / 8211.92.9030.
The complete tariff classification for the third set, item number C77TRN-15SH, will be 8211.10.0000 / 8211.92.2000.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8211.10.0000 / 8211.92.9030 and 8211.10.0000 / 8211.92.2000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty.At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheadings 8211.10.0000 / 8211.92.9030 and 8211.10.0000 / 8211.92.2000, 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 Note cited above and the applicable Chapter 99 subheading. 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/remedies/301-certain-products-china, respectively.
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/current.
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 Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division