CLA-2-73:OT:RR:NC:N1:113
Mr. Joseph W. Holdren
Sandler Travis Trade Advisory Services - A UPS Company
2031 S. Centennial Parkway
Aiken, South Carolina 29803
RE: The tariff classification of a Wing High Nut, a Hood Receiving Jig, an Anti-Attack Jig for Fr-Dr, an Anti-Attack Jig for Rr-Dr and an Anti-Attack Jig for a Lift Gate from Thailand
Dear Mr. Holdren:
In your letter dated February 12, 2021, on behalf of your client Izawa America, Inc., you requested a ruling on a Wing High Nut, a Hood Receiving Jig, and Anti-Attack Jigs used during the painting process for various vehicles. Product descriptions, photographs and technical drawings were submitted for our review.
The subject articles were identified as a Wing High Nut, a Hood Receiving Jig, an Anti-Attack Jig for Fr-Dr (front doors), an Anti-Attack Jig for Rr-Dr (rear doors) and an Anti-Attack Jig for a Lift Gate. The first item under consideration is identified as a Wing High Nut. The article is comprised of a stainless steel M6 wing nut and another internally threaded stainless steel component. The two pieces are welded together to form a single solid internally threaded fastener. The Wing High Nut is designed to secure a jig to a vehicle so that the jig does not move during the painting process. Once the painting process is completed the Wing High Nut, bolt and jig will be removed. You stated that the wing nut is not specifically designed to be used with a bolt, but could also be used with a threaded component.
The second item is identified as a Hood Receiving Jig that will be used to hold the hood of a vehicle away from the body of the vehicle during painting. You stated that the Hood Receiving Jig is assembled using various pieces of specifically shaped and designed stainless steel, and two M8 bolts with M8 nuts made of stainless steel. The pieces will be welded together including welding the bolt and nut to the main assembly, and any bolt/nut outside of the welded area will be removed by cutting off the finished assembly. The Hood Receiving Jig will be attached to the front center of the vehicle body. The jig will be used to prop open the hood of the car at a height equal to the length of the jig. The Hood Receiving Jig will be removed from the vehicle after the painting process is complete.
The third item is identified as an Anti-Attack Jig for Fr-Dr (front doors) that will be used to hold parts of a vehicle apart during the painting process. You stated that the jig is assembled by welding specifically designed stainless steel rods, blocks, and shapes together to form the complete assembly. The Anti-Attack Jig for Fr-Dr will be attached in two locations for each front door of the vehicle body including the front door itself and the front door frame on the vehicle body. The jig will hold open the front left and right doors of the vehicle body. You indicated that the opening aperture of the front doors will be proportionate to the length of the jig. The weight of the jig and the closing force of the door will secure the jig in place. The Anti-Attack Jig for Fr-Dr will be removed from the vehicle after the painting process is complete.
The fourth item is identified as an Anti-Attack Jig for Rr-Dr (rear doors) that will be used to hold parts of a vehicle body apart during the painting process. You stated that the jig is assembled by welding specifically designed and shaped stainless steel blocks, rods, and shapes to form a single piece with no moving parts. The Anti-Attack Jig for Rr-Dr will be attached in two locations for each rear door of the vehicle body including the rear door itself and the rear door frame on the vehicle body. The jig will hold open the rear left and right doors of the vehicle body. You indicated that the opening aperture of the rear doors will be proportionate to the length of the jig. The weight of the jig and the closing force of the door will secure the jig in place. The Anti-Attack Jig for Rr-Dr will be removed from the vehicle after the painting process is complete.
The fifth item is identified as an Anti-Attack Jig for a Lift Gate that will be used to keep the lift gate and body of a vehicle separated during the painting process. You stated that the jig is assembled by welding stainless steel rods and small shapes together to form one single assembly. The U-shaped hook of the jig will be inserted into a slot on the trunk door and will securely hold the jig in place. The trunk door will not be able to close at rest position. The large rectangular shape is intended to act as a handle that will allow the user to raise or lower the trunk door without touching the door itself. The Anti-Attack Jig for a Lift Gate will be removed from the vehicle after the painting process is complete.
You proposed classification for the Wing High Nut as an other threaded fastener in subheading 7318.19.0000, Harmonized Tariff Schedule of the United States (HTSUS). However this office disagrees. A review of ANSI/ASME Standard B18.12-2012, subsection 3.2.1.1. defines a nut as “a perforated block having an internal or female screw thread, designed to assemble with an external or male screw thread, such as those on a bolt or other threaded part. Its intended function is fastening, adjusting transmitting motion, or transmitting power with a large mechanical advantage and nonreversible motion.” The subject Wing High Nut is an internally threaded fastener that is designed to be assembled with a bolt or other threaded part to perform a fastening function and therefore meets the definition of a nut.
The applicable subheading for the Wing High Nut will be 7318.16.0060, 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: Nuts: Other: Of stainless steel. The rate of duty will be free.
The applicable subheading for the Hood Receiving Jig, Anti-Attack Jig for Fr-Dr, Anti-Attack Jig for Rr-Dr and Anti-Attack Jig for a Lift Gate will be 7326.90.8688, HTSUS, which provides for Other articles of iron or steel: Other: Other…Other. The rate of duty will be 2.9 percent ad valorem.
Articles classifiable under subheading 7326.90.8688, HTSUS, which are products of Thailand are currently entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP, however, is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term “GSP”.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division