Folding utility knife with quick-change blade mechanism, aluminum body, and belt clip

GRI Reasoning

Step 1 – GRI 1: Heading Identification

The product is a folding utility knife with a quick-change blade mechanism, aluminum body, and belt clip. Under GRI 1, classification is determined first by the heading text and any applicable section/chapter notes.

• Heading 8211 covers: *"Knives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof."*
• The product is unambiguously a knife with a cutting blade and is not a knife of heading 8208 (which covers knives for machines). Heading 8211 governs.
• Heading 8205 covers handtools "not elsewhere specified or included." Because this product IS specified in heading 8211 (as a knife), it cannot fall under 8205 per the NES exclusion language. The 8205 candidate is eliminated at GRI 1.

Step 2 – GRI 1/6: Subheading Selection within 8211

Within heading 8211, the relevant subheadings are:

• 8211.91 – Table knives having fixed blades → eliminated; the product is a utility knife, not a table knife.
• 8211.92 – Other knives having fixed blades → the blade in this knife folds and is quick-change (not fixed); eliminated.
• 8211.93.00 – *"Knives having other than fixed blades"* → the folding, quick-change blade mechanism confirms the blade is "other than fixed." This subheading applies.

General duty rate for 8211.93.00: 3¢ each + 5.4% (from supplied HTS data).

Column 2 ("other") rate: 35¢ each + 55%.

Footnote on 8211.93.00: References 9903.88.03, a Section 301 List 3 overlay. As the product originates in China, 9903.88.03 must be verified as an additional-duty flag (supplied Chapter 99 data confirms 9903.88.03 imposes "the duty provided in the applicable subheading + 25%" subject to enumerated exceptions). This is an additional-overlay flag to verify with a broker or trade counsel.

Step 3 – 10-Digit Statistical Suffix

Within 8211.93.00, the supplied HTS rows provide three statistical breakouts:

• 8211.93.00.31 – Folding two-handled multi-use tools (multi-tools) → not applicable; this is a single-function knife.
• 8211.93.00.35 – Pen knives, pocket knives and other knives which have folding blades → possible if CBP treats this as analogous to a pocket knife.
• 8211.93.00.60 – Other (including parts) → residual; most appropriate for a folding utility/contractor knife that is not a pen knife or pocket knife in the traditional sense.

The aluminum-body, belt-clip utility knife with quick-change mechanism is commercially distinct from a traditional pen or pocket knife. The residual suffix 8211.93.00.60 is recommended, but broker confirmation is warranted (see brokerQuestion).

Step 4 – Ruling Analysis

• N326398 (2022): Addresses country-of-origin (substantial transformation) for a utility knife with retractable steel blade and aluminum/zinc handle, belt clip — very similar product. Confirms CBP treats such articles as "utility knives" (knives), consistent with heading 8211 classification. Does not directly decide the tariff subheading, but reinforces that the article is a knife, not a hand tool under 8205.
• N362524 (2026): Classifies a 6-piece hand tool SET under 9031. Mentions a "retractable utility knife" as one component. Not directly on point for individual knife classification, but confirms CBP references the knife component in the context of heading 82 (chapter 82), consistent with 8211.
• No supplied ruling directly classifies a standalone folding utility knife under 8211.93.00 — hence MEDIUM confidence.

Step 5 – Duty Summary

| Component | Amount |

|---|---|

| General (MFN) duty | 3¢ each + 5.4% |

| Section 301 overlay (9903.88.03 flag) | + 25% (verify) |

| Column 2 rate (not applicable – China is not in column 2 status for this heading) | 35¢ each + 55% |

Step 6 – 8205 Elimination

Heading 8205 covers handtools "not elsewhere specified or included." Because the product is a knife classifiable in heading 8211, the NES exclusion in heading 8205's own terms removes it from contention. No supplied CBP ruling supports classifying a conventional folding utility knife under 8205 for this product type.