CLA-2-73:OT:RR:NC:1:118
Mr. Mathew Kemper
Crowell & Moring LLP
1001 Pennsylvania Ave., NW
Washington, DC 20004
RE: The tariff classification of steel threaded fasteners from Japan.
Dear Mr. Kemper:
In your letter dated October 19, 2010, on behalf of Aisin Holding of America Inc., you requested a tariff classification ruling.
You have submitted five threaded steel samples that you state are used in motor vehicles. Part number 432917-10480 is an M8 x 1.25 hexalobular socket head screw with a flat fillister head and an attached wave washer. It is 25 mm in length with an unthreaded guide point of approximately 6 mm. It is used in power seat assemblies. Part number 433486-10040 has a flat round shaped head with undercuts. It is referred to as a “Belt Anc. Bracket” with the letter “O” stamped on the surface. The 12 mm long threaded portion of the shank is 7/16 – 20 UNF. There is a 7 mm long shoulder with a bump that is approximately 17 mm in diameter. It is used in manual seat assemblies. Part number 432917-10440 is an M8 x 1.25 pan head hexalobular socket head screw with an unthreaded guide point of approximately 6 mm in length. The shoulder section is approximately 13 mm in diameter and 5 mm in length. It is used in power seat assemblies. Part number 143545-13010 is described as a shoe guide plate set. It has a flat trim head and the 13 mm of external threading is an M8 x 1.25. Just above the threading is a 3 mm thick hexagonal shaped collar (12 mm across flats) around the shank followed by an unthreaded section, approximately 3 mm in length, between the hexagonal collar and the unslotted head. This part is used in parking brake assemblies. Part number 131511-10420 is used in brake booster assemblies. It’s approximately 155 mm in overall length with approximately 18.8 mm of threading at one end followed by an unthreaded section of approximately 10 mm and a 2 mm collar that protrudes approximately 2 mm from the unthreaded portion of the part. On the opposite end there is approximately 37.5 mm of threading which ends at a wider round section (approximately 10 mm in diameter) with parallel knurling which butts up against a circular collar that is approximately 22 mm in diameter. The middle portion, between the two round collars, is a smooth surface approximately 77 mm from collar to collar. The ends (points) are not threaded.
The applicable subheading for part numbers 432917-10480 and 432917-10440 will be 7318.15.8045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: threaded articles: other screws and bolts, whether or not with their nuts or washers: other: having shanks or threads with a diameter of 6 mm or more: other: socket screws: other. The duty rate will be 8.5% ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
Consideration was given to classifying part number 432917-10480 within subheading 7318.15.2095, HTSUS, as an other bolt, as you suggested. This part is a socket head sems designed to be inserted into a hole and tightened by its head. This part is not described in a fastener industry dimensional standard as either a screw or bolt. Accordingly, we refer to the ANSI/ASME Standard B18.2.1. Upon review of the features of this fastener in relation to the criteria, this fastener was determined to be a screw, greater than 6 mm in diameter.
Your inquiry does not provide enough information for us to give a classification ruling on part numbers 433486-10040, 143545-13010 and 131511-10420. Your request for a classification ruling should include an explanation and drawings showing where and how the parts are actually used. Do part numbers 433486-10040, 143545-13010 aid in providing adjustment to the seat? Part number 131511-10420 appears to have a gear. Is this a moving part? Is it performing an assembly function? When this information is available, you may wish to consider resubmission of your request. We are retaining the related samples. If you decide to resubmit your request, please include all of the material that we have returned to you.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Kathy Campanelli at (646) 733-3021.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division