The tariff classification of cam levers from Germany

N361167May 15, 2026CLA-2-76:OT:RR:NC:N1:113
CATEGORY: Classification
TARIFF NO.: 7326.90.8688; 7616.99.5190
Jennifer Smith VeluzButzel Long, P.C.1909 K. Street, N.W. Suite 860Washington, DC 20006RE: The tariff classification of cam levers from GermanyDear Ms. Smith Veluz:In your letter dated
April 30, 2026
, you requested a tariff classification ruling on behalf of your client KIPPInc. Technical information was submitted with your request.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 haveopenings in their washer assemblies with internal threading.When in use, a male cam can be applied leverlike a screwdriver using the stud and handle. A female cam lever secures its objects using its internalthreading 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 t object in place.hat In your request, you suggested the cam levers are provided for in subheading 8466.20.8065, HarmonizedTariff Schedule of the United States (HTSUS), which provides for “Parts and accessories suitable for usesolely 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 anytype of tool for working in the hand: Work holders: Other: Other work holders: Other.” We disagree.Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1provides that the classification of goods will be determined according to the terms of the headings of thetariff 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 2through 6 will then be applied in order.As a primary matter, the terms of heading 8466, HTSUS, are limited to “Parts and accessories suitable for usesolely or principally with the machines of headings 8456 to 8465.”Based on the submitted documentation, although the cam levers may be used with the machine tools of headings 8456 to 8465, their use in thatcontext is not their sole or principal use.Despite their robust construction, the subject cam levers feature (or accommodate) standard, widely available, and commercially versatile thread sizes (metric and UnifiedNational Coarse/Unified National Fine). Therefore, the cam levers are fundamentally interchangeablearticles.Pertaining to the models at issue, the Kipp Inc. website echoes this stance, plainly states “Cam levers…areused wherever frequent adjustments and clamping are necessary… Cam levers can be used in almost anyindustrial application or product, from tooling and workholding to on-product adjustment and use.”The website also states “…They significantly contribute to the improvement of processes, safety and reliability indifferent application sectors… The levers are widely used in areas such as mechanical engineering,toolmaking and plant engineering. Their ability to quickly and safely carry out fastening and adjustmentprocesses makes them an efficient solution for many industrial and technical tasks.”In summary, the cam levers may be equally useful with other types of machinery, or other unrelatedapplications, and their use is neither specialized nor confined to any of the machines classified in headings8456 to 8465, HTSUS. Consequently, classification in heading 8466, HTSUS, is precluded.We note that the cam levers are composed of various materials. The classification of merchandise under theHTSUS is in accordance with the GRIs, taken in order. GRI 3(b) provides that mixtures, composite goodsials or made up of different components, and goods put up in sets for retail saleconsisting of different matershall be classified as if they consisted of the material or component which gives them their essentialcharacter. Explanatory Note (EN) VIII to GRI 3(b) explains that “the factor which determines essentialcharacter will vary as between different kinds of goods. It may, for example, be determined by the nature ofthe material or component, its bulk, quantity, weight or the use of the goods.” Since the cam levers arecomposed of different materials and each have a predominant material, the cam levers fit the description of acomposite good with their dominant material imparting the essential character. The predominant material formodel K0647.15120A2X20 is stainless steel. Therefore, that cam lever model will be classified underChapter 73, HTSUS, which covers articles made of steel. The predominant material for modelsK0005.25011A3, K0005.2501110X40, K0006.15011A2X20, and K2120.15011A2 is aluminum. Therefore,those cam lever models will be classified under Chapter 76, HTSUS, which covers articles made ofaluminum.Headings 7326 and 7616, HTSUS, are residual or basket provisions which cover a wide range of steel oraluminum articles that are not more specifically provided for elsewhere in the HTSUS. An article of steel canbe classified in heading 7326, HTSUS, and an article of aluminum can be classified in heading 7616,HTSUS, if it is determined that the item is not more specifically provided for in any other heading of thetariff. The cam levers are not specifically covered elsewhere in the tariff. Accordingly, cam lever modelK0647.15120A2X2 is classifiable in heading 7326, HTSUS, and cam lever models K0005.25011A3,0K0005.2501110X40, K0006.15011A2X20, and K2120.15011A2 are classifiable in heading 7616, HTSUS.The applicable subheading for c K0647.15120A2X2will be 7326.90.8688, am lever model0 HTSUS, whichy willprovides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of dutbe 2.9 percent ad valorem.The applicable subheading for the cam lever K0005.25011A3, K0005.2501110X40,models K0006.15011A2X20, and K2120.15011A2 will be 7616.99.5190, HTSUS, which provides for “Other articlesr: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem.of aluminum: Other: Othe
The 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 providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS.Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Matthew Gay at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division