CLA-2-73:OT:RR:NC:N5:121
Dongchun Lee
SPM Auto Parts SA de CV
Av. Internacional 240 Vynmsa Escobedo Industrial Park
General Escobedo, Nuevo Leon 66053
Mexico
RE: The tariff classification of steel wheel nuts and flange bolts from Mexico
Dear Mr. Lee:
In your letter dated May 27, 2025, you requested a tariff classification ruling.
The first item under consideration is described as an automotive wheel nut, part number 52950-14140. It is
made of chrome plated steel. You note that wheel nuts are commonly referred to as “lug nuts” and serve as
essential fasteners that secure wheels to vehicles. You also state they are specifically engineered for
automotive wheel fastening.
The second item under consideration is described as a flange bolt, part number 1081458. This fastener is
made of steel, has a flanged hex head, is partially threaded, and measures 8 mm in diameter and 100 mm in
length. You note that it is used to attach a compressor.
You propose classifying these two articles under 8708.70.6060, which provides for Parts and accessories of
the motor vehicles of headings 8701 to 8705: Road wheels and parts and accessories thereof: For other
vehicles: Parts and Accessories: Other. We disagree. Classification of merchandise under the HTSUS is
governed by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that the classification
is determined first in accordance with the terms of the headings and any relative section and chapter notes.
Because the wheel nut (lug nut) and the hex flange head fastener can be more specifically classified as
fasteners in heading 7318, Harmonized Tariff Schedule of the United States (HTSUS) they are considered
parts of general use. Section Note 2(b) to Section XVII excludes parts of general use of base metal. And as
such, classification of these two articles in heading 8708, HTSUS, is precluded. Additionally, we note
Additional U.S. Rules of Interpretation 1(c) which reads, “In the absence of special language or context
which otherwise requires … a provision for parts of an article covers products solely or principally used as a
part of such articles but a provision for “parts” or “parts and accessories” shall not prevail over a specific
provision for such part or accessory.”
You state that you currently classify the wheel nut under 7318.16.0015, which provides for non-locking,
chrome plated lug nuts, we agree with your current classification for the wheel nut/lug nut.
You state that you currently classify the flange bolt under 7318.15.8085, HTSUS, which provides for screws
having shanks or threads with a diameter of 6 mm or more…Other: Other: Other: Other. We disagree. This
fastener has a hex head with a flange. Flanges act in the same way that washers do, which is to distribute the
load under the screw head, and a flange head would be considered a cap screw. See Heads and Threads, Inc.
v. United States, C.D. 3412, aff'd. C.A.D. 960 (1969). This definition, along with other classification
guidance, can be found in the Informed Compliance Publication titled “Fasteners of Heading 7318” found at
Informed Compliance Publications | U.S. Customs and Border Protection.
The applicable subheading for the automotive wheel nut, part number 52950-14140 will be 7318.16.0015,
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…Lugnuts:
Non-locking chrome plated. The rate of duty will be free.
The applicable subheading for the flange bolt, part number 1081458 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.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheadings 7318.16.0015
and 7318.15.8066, HTSUS. Derivative iron or steel products processed in another country from steel articles
melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional
ad valorem duties. Please note that derivative steel products admitted to a U.S. foreign trade zone under
“privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025,
may be subject to additional duties under heading 9903.81.93, HTSUS.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheadings 7318.16.0015
and 7318.15.8066, HTSUS, listed above. Articles that are entered free of duty under the terms of general note
11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in
subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the
additional ad valorem duties provided for in heading 9903.01.01. If your product is entered duty free as
originating under the USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheadings
7318.16.0015 and 7318.15.8066, HTSUS.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. Your products fall within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheadings 7318.16.0015 and 7318.15.8066, HTSUS, listed
above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Jennifer Jameson at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division