HQ 954177: Blades, Ulu knife Dear Mr. Gransbury:

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                           HQ 954177 

                          July 30 1993


CLA-2  CO:R:C:M  954177 DFC 

CATEGORY:  Classification 

TARIFF NO.:  8211.94.10 

Mr. David Gransbury 
The Ulu Factory, Inc.
298 Warehouse Avenue 
Anchorage, Alaska  99501 
 
RE:  Blades, Ulu knife 
 
Dear Mr. Gransbury:

     In a letter dated April 8, 1993, you inquired as to the
tariff classification under the Harmonized Tariff Schedule of the
United States (HTSUS), of Alaska Ulu knife blades which will be
manufactured in China or Taiwan.  A sample of the blade and the
finished knife were submitted for examination.  You also inquired
as to the proper country of origin marking of the blades.  Our
response as to the country of origin marking will be the subject
of a separate letter to you.  

FACTS: 

     The Ulu knife blade has the approximate shape of a
trapezoid, but with the base curved in an arc.  It is 2-3/4
inches in height and the straight line distance between the two
ends of the curved cutting edge is approximately 5-7/8 inches. 
At the top of the blade is the tang section perforated with two
holes.  

     After importation the blades will be embellished with a
design and a wooden handle will be affixed to each blade.  In
addition the blades may have to be polished and sharpened. 

ISSUE: 

     What is the proper classification of the blades?  








                              -2- 

LAW AND ANALYSIS: 

     Classification of goods under the HTSUS is governed by the
General Rules of Interpretation (GRI's).  GRI 1 provides that
"classification shall be determined according to the terms of the
headings and any relative section or chapter notes, and, provided
such headings or notes do not otherwise require, according to
[the remaining GRI's taken in order]."  In other words,
classification is governed first by the terms of the headings of
the tariff and any relative section or chapter notes.  
                 
     Although the Ulu knife does not have the traditional shape
of a knife, it is principally used as a knife for cutting.  It is
not a chopper or mincer.  Consequently, the blades are
classifiable under subheading 8211.94.10, HTSUS, which provides
for blades for knives having fixed blades.  The applicable rate
of duty for this provision is 0.2 cents each plus 2.8% ad
valorem.

HOLDING: 

     Pursuant to GRI 1, HTSUS, the Ulu knife blades are
classifiable under subheading 8211.94.10, HTSUS. 


                                   Sincerely, 


                                   John Durant, Director 
                                   Commercial Rulings Division