CLA-2-73:OT:RR:NC:N1:121
Ms. Lauren Benway
Trans-Border Global Freight Systems
2103 Route 9
Round Lake, NY 12831
RE: The tariff classification of washers, a stud and drain plug washers from Taiwan.
Dear Ms. Benway:
In your letter dated August 7, 2017, you requested a tariff classification ruling on behalf of Marli Manufacturing.
The merchandise under consideration is five articles used in automobile engines. Submitted samples were examined and will be retained by this office.
Product number 13-02, described as a head bolt washer, is made of carbon steel. It distributes the load of an engine head bolt when fastening the engine head to the engine block. The head bolt washer ranges in size from 10 mm to 14 mm in diameter.
Product 21-08, described as a rocker arm stud, is made of carbon steel. It is threaded at both ends and has a hexagonal head located partway down the shank. The rocker arm stud serves to fasten a rocker arm to the engine head. One end of the stud is torqued into the engine head. The other end provides a protuberance upon which the rocker arm is fastened with a nut (not included).
Product number 44-03, described as a star washer, is commonly referred to as an external tooth lock washer. It is made of spring steel and is used with an oil pan bolt to secure an oil pan to an engine block.
Product number 71-15, described as an aluminum drain plug washer, is used with an oil drain plug to seal the pan. It ranges in diameter from ½ inch and 12 mm to 32 mm.
Product number 72-01, described as a copper drain plug washer, is used with an oil drain plug to seal the pan. It ranges in diameter from ½ inch and 12 mm to 32 mm.
The applicable subheading for the head bolt washer will be 7318.22.0000, 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: non-threaded articles: other washers. The general rate of duty will be free.
The applicable subheading for the rocker arm stud will be 7318.15.5090, HTSUS, which provides for Screws, bolts, nuts…and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Studs: Other: Other. The rate of duty will be free.
The applicable subheading for the star washer will be 7318.21.0090, 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: non-threaded articles: spring washers and other lock washers: other. The duty rate will be 5.8% ad valorem.
You propose classification of the aluminum and copper drain plug washers in subheading 7616.10.7090, HTSUS and 7415.21.0000, HTSUS. We disagree with your proposal because these subheadings provide for washers that are used with a nut to protect the material that is being fastened and to evenly distribute the weight upon tightening. You indicate in your letter that the subject drain plug washers are used exclusively to seal the oil pan and do not perform fastening functions.
The applicable subheading for the aluminum drain plug washer will be 7616.99.5190, HTSUS, which provides for other articles of aluminum, other, other, other, other, other, other. The rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the copper drain plug washer will be 7419.99.5050, HTSUS, which provides for other articles of copper, other, other, other, other, other. The rate of duty will be free.
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 https://hts.usitc.gov/current.
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 Barbara Kaiser at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division