The tariff classification of rope clamp ascenders from Taiwan and a quickdraw device from Italy

N361345May 28, 2026CLA-2-95:OT:RR:NC:N4:462
CATEGORY: Classification
TARIFF NO.: 7616.99.5190; 9506.99.6080
Lisa MurrinExpeditors Tradewin LLC795 Jubilee DrivePeabody, MA 01960RE: The tariff classification of rope clamp ascenders from Taiwan and a quickdraw device from ItalyDear Ms. Murrin,In your letter dated
May 7, 2026
, you requested a tariff classification ruling on behalf of your client, SalewaUSA, LLC.Samples were provided and will be returned separately.There are two articles under consideration. The first are rope clamp ascenders manufactured in Taiwan thatare available in three styles: Ropeman 1, item number 40-ROPE1, Ropeman 2, item number 40-ROPE2, andRopeman 4, item number 40-0000006000.All three styles are intended for use in mountaineering and recreational climbing and are designed to be installed on a climbing rope in conjunction with a carabiner. The devices permit controlled ascent or positioning through a manually operated camming mechanism thatlocks in one direction under load while gliding freely in the opposite direction.Ropeman 1 consists of forged aluminum side plates, an aluminum alloy cam featuring a flat tooth profile, astainless steel axle, a stainless steel cable leash, and internal springs. Available in both blue and orange,Ropeman 1 measures approximately two inches in length by one inch in width, with a curved body thatmeasures 1.25 inches at its highest point.The side plates twist openthe device to be clamped onto a to allow climbing rope.Ropeman 1 is compatible with ropes ranging from 10 millimeters to 13 millimeters in diameter and is certified to EN 567, the European safety standard for mountaineering rope clamps. Ropeman 2 differs from Ropeman 1 in that it features a stainless steel toothed cam and is available in bothblack and gold.Ropeman 4 is designed for mountaineering and rock climbing applications including emergency rescue,self-rescue, ascending, self-belay, and positioning lanyard adjustment. It has similar components toRopeman 1 yet features an additional aluminum tube and internal springs to keep one side plate closed.
Available in both black and orange, Ropeman 4 measures approximately 2.5 inches in length by 0.8 inches inwidth, with a curved body that measures 1.25 inches at its highest point.It is certified under EN 567, UIAA 126, and EN 12841:B standards. Under EN 567 and UIAA 126, the working rope range is 8 m to illimeters13 m, while under EN 12841:B, the rope range is 10 millimeters to 13 millimeters.The device isillimeters also compatible with flat and tubular webbing between 10 millimeters and 15 millimeters.The second article under consideration is the Session Quickdraw, a climbing rope connector manufactured inItaly that consists of two aluminum carabiners connected by a textile sling. The sling is composed of a 99.8percent polyamide (nylon) and 0.2 percent polyester woven dyed fabric.It measures approximately 10.75 inches in overall length and is used to connect a climbing rope to protection in rock or ice. One carabiner is designed to attach to protection and is loosely retained in one sewn end of the sling, while the carabinerintended to receive the climbing rope is tightly retained in the opposite sewn end by a rubber keeper tomaintain proper orientation. The configuration of the components serves to reduce the risk of cross loading, unintended rotation, and improper clipping during climbing.The article is imported and sold as a single unit and as a set of six units.You have requested classification of both the rope clamp ascenders and the quickdraw device under heading9506, Harmonized Tariff Schedule of the United States (HTSUS), which provides, in relevant part, for“articles and equipment for… other sports.” We agree that the rope clamp ascenders are classifiable inheading 9506 as they are specifically designed for the management and control of ropes during recreationalclimbing activities.However, we find that the quickdraw device can have a variety of other applications beyond that of sport climbing.It can be used to attach to and facilitate a connection between any two objects with an opening.Additionally, the purchaser can disconnect a carabiner from the sling and use it for a number of other purposes unrelated to sports.Carabiners are generic and interchangeable in nature, and a simple arrangement of them with the textile sling does not alter this.As a result, classification of the quickdraw device in heading 9506, HTSUS, is precluded.We note that the Session Quickdraw is composed of various materials. The classification of merchandiseunder the HTSUS is in accordance with the General Rules of Interpretation (GRI), taken in order. GRI 3(c)applies “when goods cannot be classified by reference to GRI 3 (a) or GRI 3 (b), they shall be classifiedunder the heading which occurs last in numerical order among those which equally merit consideration.” Inthis case, there are two headings “which equally merit consideration,” headings 6307, HTSUS, and 7616,HTSUS. Since heading 7616, HTSUS occurs last in numerical order, the quickdraw should be classifiedunder heading 7616, HTSUS.Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles thatare not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading7616 state that, “This heading covers all articles of aluminum other than those covered by the precedingheadings of this Chapter, or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, ormore specifically covered elsewhere in the Nomenclature.” 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 otherheading of the tariff. The quickdraw is not specifically covered elsewhere in the tariff. Accordingly, it is classifiable in heading 7616, HTSUS.The applicable subheading for the Session Quickdraw will be 7616.99.5190, HTSUS, which provides for“Other articles of aluminum: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percentad valorem.The applicable subheading for Ropeman 1, item number 40-ROPE1, Ropeman 2, item number 40-ROPE2,and Ropeman 4, item number 40-0000006000, will be 9506.99.6080, HTSUS, which provides for "Articlesand equipment for general physical exercise, gymnastics, athletics, other sports…or outdoor games…;swimming pools and wading pools; parts and accessories thereof: Other: Other: Other…Other." The rate ofduty will be 4% ad valorem.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand 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 theclassification 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 Frequently Asked Questions onthe Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.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 Sandra Walia at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division