H361779

H361779 July 10, 2026 OT:RR:CTF:CPMMA H361779 SRH CATEGORY: Classification TARIFF Nos.: 8205.59.5560 and 8205.59.7000 Ms. Jennifer M. Smith-Veluz Butzel Long, P.C. 1909 K Street, NW, Suite 860 Washington, DC 20006 Re: Request to reconsider NY N361167; Tariff Classification of Various Cam Levers Dear Ms. Smith-Veluz: This letter is in response to your correspondence, dated June 23, 2026, on behalf of NK North America Inc. (“NK”), formerly KIPP Inc. (“KIPP”), requesting reconsideration of New York Ruling Letter (“NY”) N361167, dated May 15, 2026, concerning the tariff classification of five cam levers, model numbers K0005.25011A3, K0005.2501110X40, K0006.15011A2X20, K2120.15011A2 and K0647.15120A2X20. In NY N361167, U.S. Customs and Border Protection (“CBP”) classified the subject merchandise under subheadings 7326.90.8688 and 7616.99.5190 of the Harmonized Tariff Schedule of the United States Annotated (“HTSUSA”). Subheading 7326.90.8688, HTSUSA, provides for “Other articles of iron or steel: Other: Other: Other: Other: Other” and subheading 7616.99.5190, HTSUSA, provides for “Other articles of aluminum: Other: Other: Other: Other: Other.” In your reconsideration request, you assert that this classification is incorrect, and that the subject merchandise is correctly classifiable under subheading 8466.20.8065, HTSUSA, 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 the machines; tool holders for any type of tool for working in the hand: Work holders: Other: Other work holders: Other.” Alternatively, you assert that the subject merchandise is correctly classifiable under subheading 8205.59.5560, HTSUSA, 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: Other: Other: Of iron or steel: Other: Other (including parts); and subheading 8205.59.7000, HTSUSA, which provides for “Handtools . . . Other: Of aluminum.” 2 You requested that certain information submitted in connection with this request - specifically identified confidential commercial and business proprietary information of NK (in particular, technical drawings) - be treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. The specified information will not be released to the public and will be withheld from the published version of this decision. We have reviewed NY N361167 and determined that it erroneously classified the cam levers at issue. Therefore, this ruling serves to revoke NY N361167 as explained below. As this revocation decision is being issued within 60 days of the issuance of NY N361167, pursuant to 19 U.S.C. § 1625(c)(1) and 19 C.F.R. § 177.12(b), this revocation is effective immediately. FACTS: The subject merchandise was described in NY N361167 as follows: The items under consideration are cam levers, model numbers K0005.25011A3, K0005.2501110X40, K0006.15011A2X20, K2120.15011A2 and K0647.15120A2X20. These devices are used to brace and hold objects in place to prevent movement. Each model is equipped with a metal waved handle housing a hinge pin attached to a washer assembly. In this ruling, there are two types of cam levers: male cam levers (K0005.2501110X40, K0006.15011A2X20, K0647.15120A2X20) and female cam levers (K0005.25011A3, K2120.15011A2). The male cam levers have threaded studs extending from the bottom of their washer assemblies, while the female cam levers have openings in their washer assemblies with internal threading. When in use, a male cam lever can be applied like a screwdriver using the stud and handle. A female cam lever secures its objects using its internal threading to secure itself to a male stud outside its assembly. Once the washer assembly is flush with an object, the cam lever can be tightened with the leverage of the handle and hold that object in place. The five cam levers at issue are composed of several components and consist of multiple materials. A breakdown of the components and materials for each of the five cam levers is provided below: Model K0005.25011A3: - Aluminum handle, internal thread, steel components, 2-part washer. - Total percent weight of material: Aluminum (76%), Steel (21%), Other (3%). Model K0005.2501110X40: - Aluminum handle, external thread, steel components, 2-part washer. - Total percent weight of material: Aluminum (58%), Steel (39%), Other (4%). Model K0006.15011A2X20: - Aluminum handle, external thread, adjustable, steel components, 2-part washer. - Total percent weight of material: Aluminum (55%), Steel (42%), Other (3%). 3 Model K2120.15011A2: - Aluminum handle, internal thread, steel components, all-plastic washer. - Total percent weight of material: Aluminum (76%), Steel (21%), Other (3%). Model K0647.15120A2X20: - Stainless steel handle, external thread, adjustable, stainless components, 2-part washer. - Total percent weight of material: Aluminum (0%), Steel (99%), Other (1%). Images of two of the cam levers at issue—one external thread (male), and one internal thread (female)—are included below. K0006.15011A2X20 (External Thread) Image 1 K0005.25011A3 (Internal Thread) Image 2 Information from NK’s website further describes the cam levers and provides details on their main components: Cam levers are operating parts that are used for quick and torque-free clamping of workpieces. It uses an eccentrically mounted axle to generate sufficient clamping force when actuated. This property makes it a versatile tool in many technical and industrial applications. Cam levers consist of the following main components: Lever arm: The lever arm is the main part of the cam lever. It serves as a handle and facilitates power transmission. It is made of a sturdy material such as steel or plastic and can be ergonomically shaped to make handling easier. The clamping force is generated by moving the lever arm. Eccentric axle: An eccentric axle is an axle that is mounted off-centre in the lever. It enables the actual clamping or fastening movement and is therefore the centrepiece of the cam lever. This off-centre axis converts the rotary movement of the lever arm into a linear movement that moves the clamping plate towards or away from the workpiece. Bearing or pivot point: The pivot point is the area around which the lever arm moves. Bearings are often built-in to enable low-friction movement. The pivot point enables the lever arm to rotate and supports the eccentric axis to precisely carry out the movements. 4 Clamping plate: A clamping plate is that part of the cam lever that presses directly onto the workpiece. It can be made of metal, plastic or other materials and often has a non-slip surface. The clamping plate transfers the generated force to the workpiece and holds it securely against the counter bearing.1 In describing the potential uses of the cam levers that they sell, NK states that “they are used in machine and plant construction, in toolmaking, and in medical and rehabilitation technology,” and that “[t]hey are perfect for applications that require fast and secure fastening, such as in the machine tool industry, in plant engineering or assembly technology.” Id. ISSUE: What is the proper classification of the subject cam levers? LAW AND ANALYSIS: The classification of goods under the HTSUS is governed by the General Rules of Interpretation (“GRIs”). GRI 1 provides that classification shall be determined according to the terms of the headings of the tariff schedule and any relative section

The classification of goods under the HTSUS is governed by the General Rules of Interpretation (“GRIs”). GRI 1 provides that classification shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. The HTSUS headings and subheadings (where applicable) under consideration are as follows: 7318 Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: 7326 Other articles of iron or steel: 7616 Other articles of aluminum: 7616.10 Nails, tacks, staples (other than those of heading 8305), screws, bolts, nuts, screw hooks, rivets, cotters, cotter pins, washers and similar articles: 7616.99 Other: Other: 8205 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: 1 KIPP, Cam Levers, https://www.kippusa.com/en-us/products/METRIC/Adjustable-handle-tension-lever-cam-lever/Cam-levers/c/20964?srsltid=AfmBOorZcmTv-z7ZpB_VbGFTERSNXxSmSdJYEpSL9wIIb_Hi9RhScTBU (last visited July 1, 2026). 
5 8466 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 the machines; tool holders for any type of tool for working in the hand: Note 1 to Section XV, HTSUS states, in pertinent part: 1. This Section does not cover: … (f) Articles of Section XVI (machinery, mechanical appliances and electrical goods);