Request to reconsider NY N361167; Tariff Classification of Various Cam Levers

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 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); Note 2 to Section XV, HTSUS states: 2. Throughout the tariff schedule, the expression “parts of general use” means: (a) Articles of heading 73.07, 73.12, 73.15, 73.17 or 73.18 and similar articles of other base metal, other than articles specially designed for use exclusively in implants in medical, surgical, dental or veterinary sciences (heading 90.21); (b) Springs and leaves for springs, of base metal, other than clock or watch springs (heading 9114); and (c) Articles of heading 8301, 8302, 8308 or 8310 and frames and mirrors, of base metal, of heading 8306. In chapters 73 to 76 and 78 to 82 (but not in heading 7315) references to parts of goods do not include references to parts of general use as defined above. Subject to the preceding paragraph and to Note 1 to Chapter 83, the articles of Chapter 82 or 83 are excluded from Chapters 72 to 76 and 78 to 81. Note 1 to Section XVI, HTSUS states, in pertinent part: 1. This section does not cover: … (g) Parts of general use, as defined in note 2 to section XV, of base metal (section XV), or similar goods of plastics (chapter 39); … (k) Articles of chapter 82 or 83[.] Note 2 to Section XVI, HTSUS states: 2. Subject to Note 1 to this Section, Note 1 to Chapter 84 and Note 1 to Chapter 85, parts of machines (not being parts of the articles of heading 84.84, 85.44, 85.45, 85.46 or 85.47) are to be classified according to the following rules: (a) Parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 84.09, 84.31, 84.48, 84.66, 84.73, 84.87, 85.03, 85.22, 85.29, 85.38 and 85.48) are in all cases to be classified in their respective headings; (b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 84.79 or 85.43) are to be classified with the machines of that kind or in heading 84.09, 84.31, 84.48, 84.66, 84.73, 85.03, 85.22, 85.29 or 85.38 as appropriate. However, parts which 6 are equally suitable for use principally with the goods of headings 85.17 and 85.25 to 85.28 are to be classified in heading 85.17, and parts which are suitable for use solely or principally with the goods of heading 85.24 are to be classified in heading 85.29; (c) All other parts are to be classified in heading 84.09, 84.31, 84.48, 84.66, 84.73, 85.03, 85.22, 85.29 or 85.38 as appropriate or, failing that, in heading 84.87 or 85.48. Note 2 to Chapter 82, HTSUS, states, in relevant part: Parts of base metal of the articles of this Chapter are to be classified with the articles of which they are parts, except parts separately specified as such and tool-holders for hand tools (heading 84.66). However, parts of general use as defined in Note 2 to Section XV are in all cases excluded from this Chapter. In addition, in interpreting the HTSUS, the Explanatory Notes (“ENs”) of the Harmonized Commodity Description and Coding System may be utilized. The ENs, although neither dispositive nor legally binding, provide a commentary on the scope of each heading, and are generally indicative of the proper interpretation of the HTSUS at the international level. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989). Explanatory Note (C) to Section XV provides: In general, identifiable parts of articles are classified as such parts in their appropriate headings in the Nomenclature. However, parts of general use (as defined in Note 2 to this Section) presented separately are not considered as parts of articles, but are classified in the headings of this Section appropriate to them. This would apply, for example, in the case of bolts specialised for central heating radiators or springs specialised for motor cars. The bolts would be classified in heading 73.18 (as bolts) and not in heading 73.22 (as parts of central heating radiators). The springs would be classified in heading 73.20 (as springs) and not in heading 87.08 (as parts of motor vehicles). Explanatory Note 7 to Section XV states: 7. Classification of composite articles: Except where the headings otherwise require, articles of base metal (including articles of mixed materials treated as articles of base metal under the General Interpretative Rules) containing two or more base metals are to be treated as articles of the base metal predominating by weight over each of the other metals. EN 82.05 states, in pertinent part: This heading covers all hand tools not included in other headings of this Chapter or elsewhere in the Nomenclature (see the General Explanatory Notes to this Chapter), together with certain other tools or appliances specifically mentioned in the title. It includes a large number of hand tools (including some with simple hand operated mechanisms such as cranks, ratchets or gearing). This group of tools includes: … (D) Screw drivers (including ratchet types). … (G) Vices, clamps and the like 7 EN 84.66 states, in pertinent part: With the exception of the tools of Chapter 82 and subject to the general provisions regarding the classification of parts (see the General Explanatory Note to Section XVI), this heading covers: (A) Parts of the machines of headings 84.56 to 84.65. (B) Accessories for these machines, that is, subsidiary devices used in connection with the machines, such as interchangeable devices which modify the machine so that it can perform a wider range of operations; devices to increase precision; devices which perform a particular service relative to the main function of the machine. (C) Tool holders for any type of tool for working in the hand. The very wide range of parts and accessories classified here includes: (1) Tool holders which hold, guide or operate the working tool and which permit the interchange of such tool-pieces. They are of very varied types, e.g.: Chucks; tap and drill collets; lathe tool posts; self-opening dieheads; grinding wheel holders; honing bodies for use in honing machines; boring bars; turrets for turret lathes, etc. This heading also includes tool holders for any type of tool designed for operation in the hand. Such holders are usually designed for the tools of heading 82.05 or 84.67, but this heading also includes tool holders for flexible shaft outfits. (See also the provisions of the Explanatory Notes to headings 84.67 and 85.01). (2) Work holders designed to hold and sometimes manipulate (as required for a particular operation) the part being worked by the machine. A. Classification Under Headings 7318 and 7616, HTSUS, as Parts of General Use Initially, CBP must determine whether the subject cam levers are “parts of general use” as defined by Note 2(a) to Section XV. Note 1(f) to Section XV (which covers chapter 73), excludes “articles of Section XVI.” Note 1(g) to Section XVI (which covers chapter 84), excludes “parts of general use, as defined in Note 2 to Section XV, of base metal.” It follows that, if the instant merchandise is properly classified as “parts of general use” under heading 7318, Note 1(g) to Section XVI precludes their classification under heading 8466, HTSUS. Therefore, we must consider whether the instant merchandise is properly classified as a “part of general use.” While numerous headings fall under the definition of “parts of general use,” the headings at issue here are heading 7318, HTSUS, which provides for “screws, bolts, nuts . . . and similar articles” of iron or steel, and subheading 7616.10, HTSUS, which provides for “screws, bolts, nuts . . . and similar articles” of aluminum.2 2 While subheading 7616.10, HTSUS, is not specifically listed in Note 2(a) to Section XV, it is included under the umbrella of “parts of general use” because Note 2(a) to Section XV includes “similar article of other base metal.” Articles of subheading 7616.10, HTSUS, are made of aluminum, which meets the definition of “base metal” as defined in Note 3 to Section XV, and they are similar to articles of heading 7318, HTSUS. Articles of subheading 7616.10, HTSUS, are made of aluminum, which meets the definition of “base metal” as defined in Note 3 to Section XV, and they are similar to articles of heading 7318, HTSUS. 8 There is no question that the subject cam levers have the characteristics of a fastener, in that they are used to brace and hold something in place. The key issue here is whether the cam levers meet the definition of screws, bolts, nuts, and similar articles, under heading 7318, HTSUS. Explanatory Note 73.18 defines screws, bolts, and nuts, stating that they “are threaded (in the finished state) and are used to assemble or fasten goods so that they can readily be disassembled without damage.” As discussed above, the subject cam levers have both internal and external threading. The cam levers with external threading are analogous to screws, which were specifically defined in Rocknel Fastener v. United States, 24 C.I.T. 900 (Ct. Int’l Trade 2000): “[A] screw [is defined] as ‘an externally threaded fastener capable of being inserted into holes in assembled parts, of mating with a preformed internal thread or forming its own thread, and of being tightened or released by torquing the head.’” The cam levers with internal threading are analogous to nuts. In Headquarters Ruling Letter (“HQ”) H293256, dated June 3, 2019, CBP defined a “nut” broadly as “a type of fastener which is internally threaded and often used opposite a mating bolt, holding the bolt in place and thus fastening the materials together.” Solely considering the portions of the cam levers consisting of the threaded studs (external threading) and the open washer assemblies (internal threading) may indicate that they should be classified as “screws” and “nuts,” and CBP has classified items called “cam fasteners” as “parts of general use” under heading 7318, HTSUS. See HQ H263900, dated October 19, 2016 (discussing prior rulings where steel cam fasteners were found to have the design characteristics of a screw and were therefore classified in heading 7318, HTSUS). However, as discussed above, the subject cam levers consi