CLA-2-73:OT:RR:NC:N1:121
Ms. Lauren Benway
Trans-Border Global Freight Systems
2103 Route 9
Round Lake, NY 12151
RE: The tariff classification of a dowel pin, bolt, stud, thread checker and tool from Taiwan
Dear Ms. Benway:
In your letter dated September 11, 2017, you requested a tariff classification ruling on behalf of Marli Manufacturing. At issue are five products used in the automotive industry. You have submitted a sample of each product, which will be retained by this office.
Product number 39-90, described as a dowel pin made of low carbon steel, is a hollow tube measuring approximately 18.5 mm in diameter and 19.2 mm in length. It is sized for application on specific automobile engines and serves as a guide pin to align transmission parts to the engine block.
You propose classification of the steel dowel pin in subheading 8409.91.5085, Harmonized Tariff Schedule of the United States (HTSUS). However, we disagree with your proposal because the dowel pin, which serves to align/hold in place, meets the terms of heading 7318, HTSUS. As such, per Section XV, Note 2 (a), HTSUS, the dowel pin is a “part of general use.” Parts of general use are excluded from classification in Section XVI by application of Section XVI, Note 2 (g).
The applicable subheading for product number 39-90 (steel dowel pin) will be 7318.29.0000, 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: non-threaded articles: other. The duty rate will be 2.8% ad valorem.
Product number 85-13, described as an intake manifold bolt made of medium carbon steel, is used to install the intake manifold on specific vehicles. It has an indented hex flange head, a partially threaded shank, and measures 44 mm in length and 7.9 mm in diameter. You indicate that it is torqued by the head and does not take a nut.
Consideration was given to classifying product number 85-13 as a bolt in subheading 7318.15.2065, HTSUS, as you proposed. However, a review of ANSI/ASME Standard B18.2.1, indicates that part number 85-13 is a screw.
The applicable subheading for product number 85-13 (steel intake manifold bolt) 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.
Product number 85-23, described as a double end threaded stud made of medium carbon steel, is threaded at both ends and measures 10 mm in diameter by 42.3 mm in length. One end of the stud is torqued into the engine plug. Once anchored in place, the exhaust manifold is fastened to the other end of the stud with a nut (not included).
The applicable subheading for product number 85-23 (double end threaded stud) will be 7318.15.5090, HTSUS, which provides for screws, bolts, nuts…and similar articles, of iron or steel: threaded articles: other screws and bolts, whether or not with their nuts or washers: studs: other: other. The rate of duty will be free.
Product number “TG,” identified as a thread checker, is a gauge used to determine the size of drain plugs. Made of steel, the product features nine threaded holes representing different metric fastener sizes. To use the Thread Checker, one matches an unknown drain plug to the appropriately sized hole until a positive match is made. The product serves a function similar to that of the bolt gauge described in New York Ruling Letter B86257, dated June 11, 1997.
The applicable subheading for the thread checker (TG) will be 9031.80.8085, HTSUS, which provides for measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: other instruments, appliances and machines: other: other. The rate of duty will be 1.2% ad valorem.
Product number “Tool 80-45” is described as a plastic tool that is used to remove or install an oil drain pan plug.
As Tool 80-45 is constructed solely of plastic and not classified elsewhere, the applicable subheading will be 3926.90.9996, HTSUS, which provides for other articles of plastics and articles of other materials of headings 3901 to 3914: other: other, other. The general rate of duty is 5.3 percent 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 Barbara Kaiser at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division