If we go by the premise that non-strategic is the same as tactical.. You could argue that very small nukes with low "degrading" (word help here) times and small blast radi could be considered tactical, in that they would be used to eliminate sole troops and heavily fortified bunkers, while strategic warheads have a more profound effect with even greater contaminational consequences, thus being more of an all-encompassing choice and moving from tactical weapon to beyond-the-battlefield, strategic arms.
*wheeze*
*wheeze*