CLA-2-73:OT:RR:NC:N1:121
JoAnn R. Martin
Corporate Quotations Manager
AFC Industries
3795 Port Union Road
Fairfield, Ohio 45014
RE: The tariff classification of utility pole line hardware from China and India
Dear Ms. Martin:
In your letter dated January 10, 2020 you requested a tariff classification ruling.
The first item under consideration is described as “DA Bolt Steel HDG with 4 Square Nuts”, and also referred to as a “Double Arming Bolt”. The Double Arming Bolt is made of hot dipped galvanized steel and is 5/8 inches in diameter by 22 inches in length. It is a fully threaded rod with chamfered tips on both ends and assembled with 4 square nuts, which are included. According to your request, you sell these fasteners in many different sizes. You state they are used in double crossarm construction to secure and lock in the spacing between the crossarms.
The second item under consideration is a threaded fastener described as “HD Machine Bolt Cone Point”, and also referred to as a Square Head Bolt. It is made of 316 stainless steel and is ¾ inch in diameter by 16 inches in length. The threads measure 6 inches in length. The fastener has a square head and a formed cone point. Included with the item is 1 square nut, 2 square washers, and 1 double coil spring lock washer. According to your request, you sell these fasteners in many different sizes. You state they are used for fastening pole line hardware to crossarms, poles, and other structures.
The third item under consideration is described as “Stud for Installing Thru Poles”, also referred to in the provided attachments as a “Line Post Stud”. The Line Post Stud is a hot dipped galvanized forged steel stud and is ¾ inch in diameter by 12 inches in length. It is partially threaded and assembled with 1 square nut, 1 concave locknut, 1 square washer, 1 single coil lock washer, and 1 double coil lock washer, which are included. According to your request, you sell these fasteners in many different sizes. You state they are used to secure post insulators to wood or steel crossarms.
The applicable subheading for the DA Bolt Steel HDG with 4 Square Nuts (Double Arming Bolt) will be 7318.15.5056, 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: Studs: Other: Continuously threaded rod: Other. The duty rate will be free.
The applicable subheading for the HD Machine Bolt Cone Point (Square Head Bolt) will be 7318.15.8082, 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: Other: Of stainless steel. The duty rate will be 8.5% ad valorem.
The applicable subheading for the Stud for Installing Thru Poles (Line Post 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.
The Double Arming Bolt and Line Post Stud imported from China or India may be subject to antidumping duties or countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at http://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on “Antidumping and Countervailing Duty” under “Popular Topics” at the top of the screen), and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at http://addcvd.cbp.gov/.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7318.15.5056, 7318.15.8082, or 7318.15.5090, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7318.15.5056, 7318.15.8082, or 7318.15.5090, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division