CLA-2-73:OT:RR:NC:1:118

Ms. Patti Cordo
American Cargo Express, Inc.
545 Dowd Avenue
Elizabeth, NJ 07201

RE: The tariff classification of steel fasteners from Germany.

Dear Ms. Cordo:

In your letter dated November 1, 2011, you requested a tariff classification ruling on behalf of Profile Verbindugstechnik GMBH & Co. KG. The submitted samples are being returned as requested.

You submitted seven samples for review. You have stated that these fasteners are made of steel with zinc plating or otherwise coated. They are used in the automobile, appliance and construction fittings industries. The samples are identified as follows: UMP8000009A - UMP Nut RND0813A43A - Round Rivet Nut RDN0611A25A - Round Rivet Nut RND1015A51A - Round Rivet Nut SBF0826A01A - Pierced Stud with Flange SBF0616A02A - Pierce Stud with Flange KSB0617A07A - Pierced Stud with Nut

The UMP Nut has a 7/16” internally threaded hole and an overall thickness of 5/8”. Its exterior dimensions are 13/16” x 5/8” for 3/8” in thickness and the remaining 1/4” thickness is 5/8” x 5/8”

The Round Rivet Nuts, items RND0813A43A, RND0611A25A and RND1015A51A all have the same design with a threaded hole in the center, but are of different dimensions. RND0813A43A will fit an M8 x 1.25 fastener. The overall depth is approximately 12mm. The threading covers approximately 7mm of the interior surface with an exterior diameter of 7mm. The overall exterior diameter of 20mm begins approximately 3mm up from the unthreaded section and is approximately 5mm thick. RND0611A25A will fit an M6 x 1.0 fastener. The overall depth is approximately 9mm. The threading covers approximately 7mm of the interior surface with an exterior diameter of 9mm. The overall exterior diameter of 15mm begins approximately 2mm up from the unthreaded section and is approximately 4mm thick. RND1015A51A will fit an M8 x 1.25 fastener. The overall depth is approximately 14mm. The threading covers approximately 11mm of the interior surface with an exterior diameter of 15mm. The overall exterior diameter of 25mm begins approximately 4mm up from the unthreaded section and is approximately 5mm thick.

The Pierced Studs with Flanges, items SBF0826A01A and SBF0616A02A, are externally threaded with a round hallowed out head. The upper portion of the flange has evenly spaced indentations. Item SBF0826A01A is an M8 x 1.25 fastener and SBF0616A02A is an M6 x 1.0 fastener.

Item KSB0617A07A is described as a Pierced Stud with Nut. It is an externally threaded one piece item that could be joined with an M6 x 1.0 threaded opening.

The applicable subheading for the nuts, items UMP8000009A - UMP Nut, RND0813A43A - Round Rivet Nut, RND0611A25A - Round Rivet Nut and RND1015A51A - Round Rivet Nut, will be 7318.16.0085, 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: nuts: other: other. The duty rate 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 http://www.usitc.gov/tata/hts/.

Your inquiry does not provide enough information for us to give a classification ruling for the Pierced Stud with Flange, items SBF0826A01A and SBF0616A02A or the Pierced Stud with Nut, item KSB0617A07A. Your request for a classification ruling should include the shank dimensions and thread sizing for each. How does each fastener function? What is the purpose of the hollow head? Are they held in place leaving a protuberance for something to be attached? Are they tightened with a special tool? When this information is available, you may wish to consider resubmission of your request. We are returning the samples. If you decide to resubmit your request, please include all of the material that we have returned to you. Please limit your ruling request to a maximum of 5 items of the same class or kind.

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