CLA-2-73:OT:RR:NC:N1:121
Angella R. Gonzalez
Trans-Overseas Corporation
28000 Goddard Rd.
Romulus, MI 48174
RE: The tariff classification of a steel twelve point bolt from Japan
Dear Ms. Gonzalez:
In your letter dated December 6, 2018, you requested a tariff classification ruling on behalf of Dexter Fasteners Technologies.
The article under consideration is described as a steel twelve point bolt, item number 90005-RPY-G010-M. Based on the photos and blueprint, this article is an indented twelve point flange head fastener assembled with a flat washer. It is made of steel and is partially threaded. The thread diameter is 11 mm, the thread length is 75 mm, and the overall length of the item is 177.5 mm. The article is a high-strength automotive fastener. You state that this fastener is normally assembled with a nut to clamp assembled parts.
Consideration was given to classification under 7318.15.2095, Harmonized Tariff Schedule of the United States, (HTSUS) as you proposed. However, this article would not be considered a bolt since it is capable of being turned during assembly and does not have to be assembled with a nut to perform its intended function. Based upon supplementary criteria of ASME B18.2.1, this article is classified as a screw.
The applicable subheading for steel twelve point bolt, item number 90005-RPY-G010-M will be 7318.15.8066, 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: other: with hexagonal heads: other: cap screws. 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 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