Explanatory notes
… the articles have cutting teeth, flutes, grooves, or the like, of base metal, which retain their identity and … appliances (heading 82.08) and plates, sticks, tips and the like, for tools (heading 82.09). (D) Articles of cutlery … on the floor, bench, etc. Thus a breast drill which the worker uses freely in the hand, without support, is a tool …Legal note
… the articles have cutting teeth, flutes, grooves, or the like, of base metal, which retain their identity and …