CLA-2-73:OT:RR:NC:1:118
Ms. Bess Morgan
ARRIS Group, Inc.
3871 Lakefield Drive
Suwanee, GA 30024
RE: The tariff classification of hold down screws from China.
Dear Ms. Morgan:
In your letter dated May 29, 2012, you requested a tariff classification ruling.
The hold down screws have been described as follows:
- Part number HS0208 is a 4-40 x 1.5 stainless steel slotted screw. It is used to fasten cable assemblies to electronic modules;
-Part number 1501915 is a 10-32 x 1.688 hex slotted head stainless steel screw. It is used to fasten an electronic module to a base housing;
- Part number 1500329 is an 8-32 x 2.06 steel screw. It has a deep slot centered on the diameter of the head and a chamfered point. It is used to fasten an electronic module to a base housing.
The applicable subheading for the stainless steel screws, part numbers HS0208 and 1501915, will be 7318.15.6070, 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 screws and bolts, whether or not with their nuts or washers: other: having shanks or threads with a diameter of less than 6 mm: other: of stainless steel. The duty rate will be 6.2% ad valorem.
The applicable subheading for the steel screw, part number 1500329, will be 7318.15.6080, 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 less than 6 mm: other: other. The duty rate will be 6.2% 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 http://www.usitc.gov/tata/hts/.
Consideration was given to classifying part numbers 1500329 and HS0208 as machine screws in subheading 7318.15.4000, HTSUS, as you had suggested, however, these screws were not fully threaded. Furthermore, machine screws must be 3.2 mm or more in diameter and part number HS0208 is less than 3.2 mm in diameter. Classification of part number 1501915 in subheading 7318.15.6080, HTSUS, was determined to be inappropriate as that screw was made of stainless steel, not steel.
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,
Thomas J. Russo
Director
National Commodity Specialist Division