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RULING N341177 · NY Ruling · 2024-08-05
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Knife block sets HTS 8211.10.00: why CBP prices the set by its highest-duty knife

HTS 8211.10.00.00 Base duty Set rate follows the highest-duty article: .4¢ each + 6.1% (8211.92.9030) or .8¢ each + 4.6% (8211.92.2000) Section 301 (China origin) +7.5% under 9903.88.15 — verify current Chapter 99 status and exclusions Origin China
What this is Public CBP CROSS case study · trade-compliance education · tariff-risk awareness · AI-assisted reference Not a formal HTS classification, customs-broker advice, or legal opinion for your shipment.
A · Facts Source: CBP CROSS public record
Importer's question
How should three retail knife block sets from China be classified under the HTSUS?
Product description
Three stainless-steel knife sets sold with a wooden block that has a built-in sharpener. Two 7-piece sets pair five knives plus kitchen shears with an Acacia block; both have stainless-steel blades and stainless-steel hollow handles, differing only in handle shape. The 15-piece set adds a bread knife and six steak knives, uses a Rubberwood block with sharpener and honer, and has ABS plastic handles (with stainless butts and fasteners).
CBP holding
CBP classified all three sets as sets of assorted articles under 8211.10.0000, then applied the duty of the single article in each set carrying the highest rate — the 3.5-inch paring knife (8211.92.9030 for the steel-handle sets, 8211.92.2000 for the plastic-handle set). Section 301 duty of 7.5% under 9903.88.15 also applies.
CBP reasoning
Because the items are put up together for retail sale, heading 8211 covers them as a set. Under the set rule, the whole set is dutiable at the rate applicable to the component subject to the highest rate. Here the paring knife carried the highest combined ad valorem rate once the 7.5% Section 301 add-on was factored in, so it drives the number for each set. Handle material split the paring-knife subheading: steel handles fell in 8211.92.9030, plastic-predominant handles in 8211.92.2000.
Basis
GRI 1GRI 3(b)
Verify against the original: rulings.cbp.gov/ruling/N341177 ↗ · this layer paraphrases the public record; the CROSS original controls.
B · Case analysis ETDETA original analysis · educational

CBP classified three China-origin knife block sets under HTS 8211.10.00.00 as sets of assorted articles, but the duty rate is set by the single highest-rate knife in each set (the 3.5-inch paring knife), plus a 7.5% Section 301 add-on under 9903.88.15.

02Why this heading, and not the obvious one

Heading 8211 covers knives with cutting blades plus their base-metal parts, and it has a dedicated subheading, 8211.10.00.00, for 'sets of assorted articles.' Because these are five to fifteen cutting implements plus shears and a wood block put up together for retail sale, GRI 1 and the set structure of the heading point straight to 8211.10. The obvious alternative would be to break the pack apart and classify each knife on its own line (e.g. the chef knife under 8211.92) or to treat the wooden block as furniture or a wood article of Chapter 44. CBP did neither. The set rule in 8211.10 says the whole set is dutiable at the rate of the article in it carrying the highest rate. So the paring knife — the highest-rate piece once Section 301 is layered in — governs the number. Handle material then decides the paring-knife subheading: steel handles land in 8211.92.9030, plastic-predominant handles in 8211.92.2000. The wood block rides along with the set rather than being classified separately.

03What it means for importers
  • Confirm which knife in your set carries the highest combined rate — that piece, not an average, sets the duty for the whole set.
  • Check handle material on that governing knife: steel vs. plastic changes the specific + ad valorem rate.
  • Verify current Section 301 status under 9903.88.15 before entry and budget the +7.5% into landed cost.
04Duty impact of the two paths
PathCodeBase duty
Set with steel-handle paring knife (as CBP applied)8211.10.0000 / 8211.92.9030.4¢ each + 6.1%
Set with plastic-handle paring knife illustrative8211.10.0000 / 8211.92.2000.8¢ each + 4.6%
On a shipment of 1,000 seven-piece steel-handle sets valued at $20 each ($20,000): base duty at 6.1% ad valorem = $1,220, plus the .4¢-per-knife specific component on the governing knives. The plastic-handle 15-piece set instead runs 4.6% + .8¢ each. Add Section 301 at 7.5% ($1,500 on the $20,000) only if the goods remain subject to that measure at entry — confirm current Chapter 99 status and any exclusion before relying on this; we do not stack a fixed combined rate here.

Illustrative comparison only. The alternative heading is one contrast possibility — the exact subheading for a different product configuration would need separate analysis (other Chapter 84/85 or specific provisions may apply). Any Section 301 / Chapter 99 figure assumes the goods remain subject to that measure at the time of entry; always verify the current Chapter 99 status and any applicable exclusions.

05Compliance risk flags
  • Assuming the whole set takes the lowest knife's rate — the set rule uses the highest-rate article instead.
  • Getting the handle material wrong on the governing knife swaps the subheading and the specific-duty amount.
  • Treating Section 301 as fixed — the 9903.88.15 add-on and any exclusions change; verify at time of entry.
07If the product changes (edge cases)
  • The block or gadgets dominate the set (e.g. many non-knife kitchen tools added) → CBP may look past 8211 and analyze the set's essential character differently, possibly changing the governing heading.
  • The governing paring knife's handle switches from steel to plastic (or vice versa) → Subheading moves between 8211.92.9030 and 8211.92.2000, changing both the specific cents-each and the ad valorem rate.
  • Origin shifts from China to a non-301 country → The 7.5% 9903.88.15 add-on drops out, though the base 8211 rate and specific duty still apply.
08Practitioner's takeaway

The trap on knife sets isn't the heading — 8211.10 is well settled — it's remembering the set is duties at the highest-rate knife in the box, not an average. On China origin, the paring knife plus Section 301 usually decides the whole line, so cost that in early.

09Importer checklist — what to prepare for similar products
  • List every knife and non-knife item in the set, with blade lengths and functions.
  • Identify the single highest-rate piece and confirm its handle material (steel vs. plastic).
  • State on the invoice that items are put up together for retail sale as one set.
  • Note the block material (Acacia, Rubberwood) and whether it has a built-in sharpener/honer.
  • Record country of origin and check current 9903.88.15 Section 301 status and exclusions.
  • Keep this ruling's control number handy for entry if your product genuinely matches.
FAQFrequently asked questions

Why are knife block sets classified under HTS 8211.10.00 instead of splitting each knife out?

Because the items are put up together for retail sale, heading 8211 has a specific subheading for 'sets of assorted articles.' In this ruling CBP kept the sets whole under 8211.10.00.00 and applied the highest-rate article's duty. Your own set should be confirmed with a licensed customs broker.

How is the duty rate on a knife set actually calculated?

The set is dutiable at the rate of the single article in it carrying the highest rate. In N341177 that was the 3.5-inch paring knife once Section 301 was factored in, so its subheading drove the number for the whole set.

Does Section 301 apply to China-origin knife sets under 8211.10.00?

In this ruling CBP flagged an additional 7.5% under 9903.88.15 for the China-origin sets. That rate and any exclusion can change, so verify current Chapter 99 status at the time of entry.

Why did two sets fall in 8211.92.9030 but the third in 8211.92.2000?

The governing paring knife's handle decided it. The two steel-handle sets used 8211.92.9030 (.4¢ each + 6.1%); the ABS plastic-handle set used 8211.92.2000 (.8¢ each + 4.6%).

Does the wooden knife block get classified separately from the knives?

No. In this ruling the Acacia and Rubberwood blocks with built-in sharpeners rode along as part of the retail set rather than being classified on their own line.

Would adding lots of kitchen gadgets change the classification?

It could. A set dominated by non-knife tools may be analyzed differently for essential character, as in the 51-piece cutlery-and-gadget ruling. Final classification depends on your actual product and should be confirmed by a licensed customs broker.

This section is an educational reading of a public ruling, written to help importers understand classification reasoning and tariff risk. It does not make a classification decision about your specific goods.
BW
Founder & CEO, ETDETA · 30+ years in trans-Pacific ocean shipping; earlier at APL, COSCO, SEALAND and P&O; founded ETDETA in 2005.
PA
Co-Founder & COO, ETDETA · 30+ years in Asia-Pacific shipping and logistics; earlier at Evergreen, Yang Ming and KMTC.
Research & editorial: ETDETA Trade Research Group · reviewed before publication. General educational information, not a determination.
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This is general educational information compiled from public CBP CROSS rulings to help importers understand classification reasoning, duty differences and compliance risks. It is not a formal HTS classification, customs-broker service, entry instruction, duty determination, or legal advice for any specific shipment. Final classification depends on a product's actual material, construction, use, accessories, invoice description, country of origin, and current legal status. Importers should confirm with a licensed customs broker or trade counsel, or request a binding ruling from CBP, before entry.