N354094

N354094 September 30, 2025 CLA-2-82:OT:RR:NC:N1:118 CATEGORY: Classification TARIFF NO.: 8203.20.6030; 9903.01.24; 9903.01.25; 9903.88.03 Tianqi Jiang Burlington Coat Factory Warehouse Corporation 1830 Route 130 North Burlington, NJ 08016 RE: The tariff classification of a 10 Piece Pliers & Wrench Set from China Dear Ms. Jiang: In your letter dated September 23, 2025, you requested a tariff classification ruling. The merchandise under consideration is identified as a 10 Piece Pliers & Wrench Set, style name EU-PLS10A. The pictures you provided indicate that the set will be imported packaged for retail sale and will include the following items: 1 – 8-inch groove joint pliers 1 – 7-inch locking pliers 1 – 6-inch linesman’s pliers 1 – 6-inch slip joint pliers 1 – 6-inch adjustable wrench 1 – 6-inch diagonal pliers 1 – 6-inch long nose pliers 1 – mini long nose pliers 1 – mini diagonal pliers 1 – mini needle nose pliers The 10 Piece Pliers & Wrench Set is imported in a single retail package that contains articles that are classifiable under different headings of the tariff. The Explanatory Notes represent the official interpretation of the Harmonized Tariff Schedule (HTS) at the international level. General Rule of Interpretation (GRI) 3 applies when goods are put up for sale collectively and are classifiable under two or more headings of the tariff. GRI 3(b) covers goods put up in sets for retail sale. Explanatory Note X to GRI 3(b) defines “goods put up in sets for retail sale.” Such goods: (a) consist of at least two different articles that are classifiable in different headings, (b) consist of products put up together to meet a particular need or carry out a specific activity, and (c) are put up in a manner suitable for sale directly to users without repacking. The subject articles in the 10 Piece Pliers & Wrench Set, in our opinion, meet the criteria for sets as the terms are defined in the cited Explanatory Note. Therefore, for the purposes of the HTS, the merchandise constitutes a set. Having determined that the items constitute a set for tariff classification purposes, we must decide the essential character. According to the Explanatory Note to GRI 3(b), essential character may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of the constituent material in relation to the use of the goods. In this case, we find that the pliers impart the essential character to set. The applicable subheading for the 10 Piece Pliers & Wrench Set will be 8203.20.6030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof: pliers (including cutting pliers), pincers, tweezers and similar tools, and parts thereof: other: other (except parts): pliers. The general rate of duty will be 12¢/doz. + 5.5 percent ad valorem. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 8203.20.6030, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8203.20.6030, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8203.20.6030, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8203.20.6030, 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/programs-administration/trade-remedies, respectively. The tariffs and additional 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/. 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 anthony.e.grossi@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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 anthony.e.grossi@cbp.dhs.gov. 
Sincerely,
 (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division