CLA-2-73:OT:RR:NC:N5:121
Ronny Chiang
Everlast Industries, LLC.
643 South Hills Rd
Bloomfield Hills, MI 48302
RE: The tariff classification of a steel automotive fastener from Taiwan
Dear Mr. Chiang:
In your letter dated July 5, 2025, you requested a tariff classification ruling.
The article under consideration is described as a hexalobular socket bolt, Part number 11602136. This socket
head screw is made of steel with a zinc coating. It measures 5 mm in diameter and 17.6 mm in length. You
note that it is “specifically engineered and dimensioned for application in automotive manufacturing, with
tolerances and features unique to the automotive industry” and that it will be used exclusively in the assembly
of General Motors vehicles.
You suggest classifying the fastener in subheading 8708.99.8180, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for motor vehicles parts and accessories. We disagree.
Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). GRI
1 provides that the classification of goods shall be determined according to the terms of the headings of the
tariff schedule and any relative section or chapter notes. In addition, in interpreting the HTSUS, the
Explanatory Notes (ENs) of the Harmonized Commodity Description and Coding System may be used. The
ENs, although not dispositive or legally binding, provide a commentary on the scope of each heading, and are
generally indicative of the proper interpretation of the HTSUS. See T.D. 89-80, 54 Fed. Reg. 35127 (August
23, 1989).
Note 2(b) to Section XVII, excludes “parts of general use”, as defined in Note 2 to Section XVI. The ENs to
Section XVII list such articles, in pertinent parts, as “…nails, bolts, nuts, washers, cotters and cotter-pins,
springs (including leaf springs for vehicles) (such goods of base metals fall in Chapters 73 to 76 and 78 to 81,
and similar goods of plastics fall in Chapter 39)...” Although the subject hexalobular head socket screw may
be a specialized screw for use in motor vehicles, it is nevertheless still a screw, which would be classifiable in
chapter 73. As a result, classification of the fastener in heading 8708, HTSUS, is precluded.
The applicable subheading for the hexalobular socket bolt, Part number 11602136 will be 7318.15.6040,
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: Socket screws: Other. The duty rate will be
6.2% 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 25 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 50 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 subheading 7318.15.6040,
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.
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,
including Taiwan, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry,
you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition
to subheading 7318.15.6040, 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)
James Forkan
Acting Director
National Commodity Specialist Division