Chef's knife with 8 inch high-carbon stainless steel blade and pakkawood handle

GRI Reasoning

GRI 1 – Heading Selection

A chef's knife with a fixed 8-inch high-carbon stainless steel blade falls squarely within heading 8211: *"Knives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof."* Chapter 82 contains no note excluding kitchen/chef's knives from 8211. Heading 8215 (spoons, forks, ladles, butter-knives, etc.) does not describe a chef's knife. Heading 8211.10.00 (sets of assorted articles) does not apply because this is a single knife, not a set.

GRI 6 – Subheading Selection

Within 8211, the relevant subdivision structure is:

• 8211.91 – Table knives having fixed blades → A chef's knife is not a table knife; table knives are place-setting cutlery. Ruled out.
• 8211.92 – Other knives having fixed blades → Correct subdivision; a chef's knife is a kitchen knife with a fixed blade, not a table knife.

Within 8211.92, the handle-material break applies:

• *With rubber or plastic handles* → 8211.92.20.00 (kitchen and butcher knives) / 8211.92.40 (other)
• *Other* → 8211.92.60.00 (hunting knives with wood handles) / 8211.92.90 (other)

Pakkawood is a resin-stabilized/impregnated wood composite. It retains wood fiber as its base material and is commonly treated by CBP as a wood-type handle rather than a rubber or plastic handle. Under that characterization, the handle is neither rubber nor plastic, and the knife is not a hunting knife; therefore 8211.92.90 (Other) applies at the 8-digit level.

At the 10-digit statistical level, 8211.92.90 breaks into:

• 8211.92.90.30 – Kitchen and butcher knives
• 8211.92.90.45 – Sheath-type knives
• 8211.92.90.60 – Other

A chef's knife is unambiguously a kitchen knife → 8211.92.90.30.

Duty Rate

• General (Column 1): 0.4¢ each + 6.1% (from 8211.92.90 row in supplied HTS data)
• Column 2 (Other): 8¢ each + 45%
• Section 301 China overlay: The 8211.92.90 row carries a footnote referencing 9903.88.15, which per the supplied Chapter 99 data imposes *"the duty provided in the applicable subheading + 7.5%"* for articles of China covered by U.S. note 20(r)/(s). This is an additional-overlay flag to verify — the 7.5% Section 301 surcharge appears applicable but must be confirmed against the current U.S. note 20(s) enumerated subheadings list.

Duty Estimate (annual)

• Declared unit value: $6.50; annual units: 7,000; total value: $45,500
• Base general rate: 0.4¢ × 7,000 = $28 + 6.1% × $45,500 = $2,775.50 → ~$2,803.50
• If 9903.88.15 applies: additional 7.5% × $45,500 = $3,412.50
• Total estimated duty (if Section 301 confirmed): ~$6,216

Ruling Analogy

Ruling 967755 (HQ, 2005) classified a chef's knife within a multi-knife set under 8211.92.20 (kitchen and butcher knives, plastic handles). It confirms that chef's knives belong in 8211.92 as kitchen knives, and that handle material drives the sub-subdivision. Ruling H248109 (2015) similarly confirms 8211.10.00 for full knife sets and identifies chef's knives as part of 8211.92. Neither ruling addresses a single chef's knife with a wood-composite handle, hence MEDIUM confidence.

Why Alternatives Are Rejected

• 8211.10.0000: Sets only; single knife → not applicable.
• 8211.91.xx: Table knives (place-setting cutlery); a chef's knife is a kitchen tool, not a table knife.
• 8215.99.xx: Covers spoons, forks, ladles, butter-knives, etc.; GRI 1 directs fixed-blade chef's knives to 8211, not 8215.