Folding hex key wrench set, metric and SAE, chrome-vanadium steel with plastic grip handles

GRI Reasoning

Step 1 — Identify the Goods

The product is a folding hex key wrench set containing both metric and SAE sizes, made of chrome-vanadium steel with plastic grip handles, packaged together for retail sale, originating from Taiwan.

Step 2 — GRI 1: Heading-Level Analysis

Heading 8204 — "Hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives or extensions; base metal parts thereof."

Hex key wrenches (Allen wrenches) are nonadjustable hand wrenches used for driving hex socket fasteners. They squarely fit the plain language of 8204.11.00 (nonadjustable hand-operated spanners and wrenches). The chrome-vanadium steel construction is consistent with metal hand tools. The plastic grip handles are a common feature and do not change the essential character as a hand wrench.

Subheading selection within 8204.11.00:

• 8204.11.00.30: Open-end, box and combination open-end and box wrenches — does not describe hex keys.
• 8204.11.00.60: Other (including parts) — residual provision, captures hex key wrenches not described in .30.

→ 8204.11.00.60 is the correct statistical breakout for a hex key wrench set where all tools fall under 8204.11.

Step 3 — Is 8206 Triggered?

Heading 8206 applies to "tools of two or more of headings 8202 to 8205, put up in sets for retail sale." The verified rulings (K84252, J85874, D89560, 813751) all classify multi-heading tool sets (pliers + wrenches + screwdrivers + hammers, etc.) under 8206. In those cases, the hex keys were merely one component among tools from multiple headings.

The product here is a hex-key-only set — all items are nonadjustable hex wrenches classifiable under 8204.11.00. If all components fall within a single heading/subheading, 8206 is not triggered (8206 expressly requires tools of *two or more* of headings 8202–8205). Therefore, classification remains within 8204.11.00.60.

However, if CBP views the metric and SAE keys as classifiable under different subheadings (e.g., one group under .30 and another under .60, or any component under a different heading), the set analysis could shift — though this is unlikely since all hex keys are the same type of nonadjustable wrench.

Step 4 — 8205.59 / 8205.90 Consideration

8205 covers handtools "not elsewhere specified or included (NES/NEC)." Because hex key wrenches are specifically provided for in heading 8204 as nonadjustable hand wrenches, they are "elsewhere specified" and 8205 does not apply per the NES/NEC hierarchy. 8205.70.00 (vises, clamps) is entirely inapplicable.

Step 5 — Duty Rate

For 8204.11.00, the general (MFN) duty rate is 9%. Taiwan is not a free-trade partner under the listed special rate countries, so the 9% MFN rate applies.

The column 2 ("other") rate is 45% — not applicable for Taiwan.

Section 301 overlay: The 8204.11.00 HTS row carries a footnote referencing 9903.88.03, which is a Section 301 additional tariff applicable to products of China (duty + 25%). Since this product originates from Taiwan, 9903.88.03 does not apply. No additional Section 301 duty is imposed on Taiwan-origin goods.

Step 6 — Effective Duty

• MFN general rate: 9% on declared value
• Section 301 (9903.88.03): Not applicable (Taiwan origin)
• Effective rate: 9% ad valorem
• Annual duty estimate: 8,000 units × $3.20 × 9% = $2,304

Summary

Best classification: 8204.11.00.60 — Nonadjustable hand-operated spanners and wrenches: Other (including parts). Confidence is MEDIUM because no CBP ruling directly addresses a standalone hex-key-only retail set; all on-point rulings involve multi-heading sets where hex keys appear as one component among many.