Irwin Industrial Tool Company v. United States, 920 F.3d 1356

Irwin Industrial Tool imported several hand tools (straight, large, curved, and long-nose locking pliers, some with wire cutters). U.S. Customs classified them as "wrenches" under HTSUS 8204.12.00; Irwin protested and sued in the Court of International Trade (CIT).
The CIT (Trade Court) construed the tariff terms: it defined "wrenches" as an eo nomine term describing a single‑handled tool with jaws or sockets to fit and turn fasteners, and "pliers" as a two‑handled pivoting tool squeezed to grasp objects (locking pliers included).
The Trade Court denied the government’s motion (that the tools were wrenches) and granted Irwin’s motion for summary judgment that the tools are pliers under HTSUS 8203.20.6030.
The government appealed, arguing the definitions should be use‑based (wrenches designed to apply torque/turn; pliers not including locking tools because locking permits torque akin to wrenches).
The Federal Circuit reviewed tariff term interpretation de novo, applied the General Rules of Interpretation, relied on dictionary and ASME/industry sources, adopted the Trade Court’s definitions, and noted headings are eo nomine and not use‑limited.

Issue	Irwin's Argument	Government's Argument	Held
Proper classification of imported tools under HTSUS	Tools are "pliers" as defined by physical features (two handles, two pivoting jaws, squeezed to grasp); locking pliers are a subtype	Tools are "wrenches" or should be defined by use (turning/twisting/applying torque); locking pliers primarily enable torque so are wrenches	Affirmed: Tools are pliers under 8203.20.6030; TAR headings are eo nomine and not defined by use
Whether "pliers" or "wrenches" should be defined by use	Pliers and wrenches are defined by physical characteristics; use should not be read into eo nomine headings	Tariff terms inherently suggest use; definitions should account for function (e.g., turning/torque)	Held: Neither heading requires a use limitation; definitions based on common/commercial (physical) meanings
Scope of eo nomine headings (include all forms)	Eo nomine headings include all forms unless the name inherently suggests use	Counter: some forms (locking) functionally act like wrenches and should be excluded from pliers	Held: Eo nomine presumption applies; locking pliers are a subtype of pliers and remain within the heading
Standard of review for tariff term interpretation	Adopt Trade Court’s reasoned definition; de novo review proper but give weight to CIT	Same standard applies; no dispute on standard	Court applied de novo review, gave weight to Trade Court, and affirmed its interpretations

Carl Zeiss, Inc. v. United States, 195 F.3d 1375 (Fed. Cir.) (eo nomine terms ordinarily include all forms; do not read a use limitation unless inherent)
Orlando Food Corp. v. United States, 140 F.3d 1437 (Fed. Cir.) (two‑step tariff classification: interpret headings, then apply to merchandise)
Roche Vitamins, Inc. v. United States, 772 F.3d 728 (Fed. Cir.) (de novo review of tariff interpretation)
Home Depot U.S.A., Inc. v. United States, 491 F.3d 1334 (Fed. Cir.) (review standards for classification and summary judgment)
Schlumberger Tech. Corp. v. United States, 845 F.3d 1158 (Fed. Cir.) (weight given to Trade Court’s informed opinions in tariff interpretation)
Nan Ya Plastics Corp. v. United States, 810 F.3d 1333 (Fed. Cir.) (respecting CIT’s factual and interpretive findings)
Kahrs Int’l, Inc. v. United States, 713 F.3d 640 (Fed. Cir.) (product design linked to use does not necessarily create a use limitation)
Len‑Ron Mfg. Co. v. United States, 334 F.3d 1304 (Fed. Cir.) (example where tariff language signaled a use limitation)
Marubeni Am. Corp. v. United States, 35 F.3d 530 (Fed. Cir.) (precedent from non‑identical provisions carries limited persuasive weight)
Mitsubishi Int’l Corp. v. United States, 182 F.3d 884 (Fed. Cir.) (decisions under prior statutes or by non‑binding courts are not controlling)