Furthermore, the "regulation" quoted above makes no reference to tools, only to "goods". In common commercial language "goods" usually means "stuff for sale" which normally wouldn't include tools (unless of course they were being imported to be sold.)

So if the word "tools" doesn't appear in the regulation, why does it appear on the declaration card? It would seem to be someone's interpretation of the definition of a word, that may or may not be in line with the common usage of the word.