CLA-2-88:OT:RR:NC:N1:106
Gail P. Mason
Airbus Americas, Inc
21780 Filigree Court
Ashburn, VA 20147
RE: The tariff classification of Bolt Assembly from Germany
Dear Ms. Mason:
In your letter dated June 28, 2011 you requested a tariff classification ruling. You included illustrative graphs with your request.
The items under consideration have been identified as Bolt Assembly/Item 110B, and the individual components that make up the assembly: Eccentric Bolt/Item 112, Insert/Item 156, Bolt/Item 120, Roller Assembly/Item 140A, and Bearing/Item 142 (Part of Roller Assembly). You state that all components are manufactured of stainless steel.
The Bolt Assembly is used to attach the flap to track and to allow for the extension and retraction of a flap of an aircraft. The assembly is only used within the flap structure.
The function of the Roller Assembly is to allow the extension and retraction movements of the flap. This part contains a quantity of two of Bearings. The function of the Bearings is to reduce friction. You state that this part is designed under an SAE aerospace standard number AS81934 and is used in several areas of various aircraft such as doors, fuselage, flap, etc.
The Bolt maintains the roller which is around the eccentric bolt. This part fastens the roller but does not transmit motion. It is a hexagonal bolt with a thread diameter of .25 inches, which is used in several areas of various aircraft such as doors, fuselage, flap, etc.
The applicable subheading for the Bolt Assembly and its parts Roller Assembly and Bearing will be 8803.30.0030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts of goods of heading 8801 or 8802: Other parts of airplanes or helicopters: For use in civil aircraft: Other. The duty rate will be Free.
The applicable subheading of the Bolt/Item 120 with undrilled shank will be 7318.15.8055, which provides for “…Bolts… of iron or steel: Threaded articles: Other…: Other: Having shanks or threads with a diameter of 6mm or more: Other: Other: With hexagonal heads: Of stainless steel”. The rate of duty will be 8.5 percent ad valorem.
In alternative, the applicable subheading of the Bolt/Item 120 with optional drilled shank will be 7318.15.2061, which provides for “…Bolts…of iron or steel: Threaded articles: Other…: Bolts and bolts and their nuts or washers entered or exported in the same shipment: Having shanks or threads with a diameter of 6mm or more: Other: With hexagonal heads: Of stainless steel.” 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 on Eccentric Bolt, Insert and Bolt. Your request for a classification ruling should include:
Item 112-Eccentric Bolt:
What parts does it connect? Does it connect to the flap? Describe in details.
How does it provide the attaching function?
Item 156-Insert:
Requested Sample has not been submitted for examination.
Are these helical coils on the exterior of a solid surface?
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Matthew Sullivan at (646) 733-3013.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division