CLA-2-73:OT:RR:NC:N1:121
Mr. Andreas Blöennigen
WITTE Automotive
Hoeferstrasse 3-15
Velbert, Germany 42551
RE: The tariff classification of a mechanical screw-nut system from Germany
Dear Mr. Blöennigen:
In your letter dated December 21, 2017 you requested a tariff classification ruling. The sample you submitted was examined and will be retained in this office.
The article under consideration is described as a mechanical screw-nut system and is identified as a WITOL, part number 01011281000. The WITOL is used to fasten together two components of an automobile while maintaining a specific amount of space between the components. It is made up of four pieces: 1) the bottom element is a plastic ring with two hooks that clip into one of the components and holds the WITOL in place until a screw is inserted; 2) seated inside the holding ring is a reverse threaded steel nut; 3) threaded inside the nut is a reverse externally threaded steel barrel with a washer at its top; and 4) inside the externally threaded barrel/washer is a steel spring. The WITOL is hooked into one of the auto components and the second auto component is placed at the required distance apart from the first component. A bolt is inserted through the second component and through the WITOL. The internal spring allows the bolt to pass through the WITOL while providing tension to hold the bolt in place. As the bolt turns clockwise, it backs the barrel out of the nut, tightening it into position at the height of the second component. Thus, the WITOL maintains the required space between the two automobile components while fastening them together.
The WITOL is a composite good because it is made of more than one component: the steel nut, threaded barrel and washer, and spring; as well as the plastic ring with hooks. The Explanatory Notes to the Harmonized Tariff Schedule of the United States (HTSUS), General Rule of Interpretation (GRI) 3 (b) (VIII), state that the factor which determines essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. Under GRI 3 (b), the essential character of this steel/plastic article is imparted by the steel nut, threaded barrel and washer, and spring – the components which provide the specialized function and make up the majority of the article.
The applicable subheading for the WITOL will be 7318.19.0000, 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: Threaded articles: Other. The rate of duty will be 5.7% 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 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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division