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HQ 954177

July 30 1993

CLA-2 CO:R:C:M 954177 DFC


TARIFF NO.: 8211.94.10

Mr. David Gransbury
The Ulu Factory, Inc.
298 Warehouse Avenue
Anchorage, Alaska 99501

RE: Blades, Ulu knife

Dear Mr. Gransbury:

In a letter dated April 8, 1993, you inquired as to the tariff classification under the Harmonized Tariff Schedule of the United States (HTSUS), of Alaska Ulu knife blades which will be manufactured in China or Taiwan. A sample of the blade and the finished knife were submitted for examination. You also inquired as to the proper country of origin marking of the blades. Our response as to the country of origin marking will be the subject of a separate letter to you.


The Ulu knife blade has the approximate shape of a trapezoid, but with the base curved in an arc. It is 2-3/4 inches in height and the straight line distance between the two ends of the curved cutting edge is approximately 5-7/8 inches. At the top of the blade is the tang section perforated with two holes.

After importation the blades will be embellished with a design and a wooden handle will be affixed to each blade. In addition the blades may have to be polished and sharpened.


What is the proper classification of the blades?


Classification of goods under the HTSUS is governed by the General Rules of Interpretation (GRI's). GRI 1 provides that "classification shall be determined according to the terms of the headings and any relative section or chapter notes, and, provided such headings or notes do not otherwise require, according to [the remaining GRI's taken in order]." In other words, classification is governed first by the terms of the headings of the tariff and any relative section or chapter notes.

Although the Ulu knife does not have the traditional shape of a knife, it is principally used as a knife for cutting. It is not a chopper or mincer. Consequently, the blades are classifiable under subheading 8211.94.10, HTSUS, which provides for blades for knives having fixed blades. The applicable rate of duty for this provision is 0.2 cents each plus 2.8% ad valorem.


Pursuant to GRI 1, HTSUS, the Ulu knife blades are classifiable under subheading 8211.94.10, HTSUS.


John Durant, Director
Commercial Rulings Division

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