CLA-2-73:OT:RR:NC:N5:121
Jack Chang
JFS CHB INC
385 S Lemon Ave, # E180
Walnut, CA 91789
RE: The tariff classification of steel automotive screws from Taiwan
Dear Mr. Chang:
In your letter dated July 16, 2025, you requested a tariff classification ruling on behalf of Sumeeko Industries
Co., Ltd.
The merchandise under consideration is described as indented hex washer head automotive screws. Part #
000000011602136 and Part # 000000011548002 measure 5 mm in diameter, and Part # 000000011519375
measures 6 mm in diameter. All items are made of steel. You state all three screws are custom-engineered
parts designed specifically for automotive use and for a specific make of motor vehicle.
You suggest that the subject items are correctly classified under subheading 8708.80., Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of
headings 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Suspension
systems (including shock absorbers): Parts: 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. Note 2(b) to Section XVII, which includes Chapter 87, provides that if the article is classifiable
as a “part of general use” of base metal, classification as a part or accessory in heading 8708 is precluded.
"Parts of general use" are defined in Note 2, Section XV, HTSUS, among other things, base metal
articles of heading 7318, HTSUS. Heading 7318 includes, in pertinent part, Screws, bolts, nuts, coach screws,
screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or
steel. In addition, the Explanatory Notes (EN) to Section XV provide that in general,
identifiable parts of articles are classified as such parts in their appropriate headings in the Nomenclature.
However, “parts of general use” presented separately are not considered as parts of articles but are classified
in the headings of this Section appropriate to them. This applies even if the component has a limited or
specialized function. We find that the subject bolts and screws are more specifically provided for in heading
7318, HTSUS. As such, they are “parts of general use” per Note 2(a) to Section XV and are precluded from
classification in heading 8708, HTSUS.
The applicable subheading for the 5 mm diameter screws, Part numbers 000000011602136 and
000000011548002, will be 7318.15.6080, 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: Other.”
The duty rate will be 6.2 percent ad valorem.
The applicable subheading for the 6 mm diameter screws, Part number 000000011519375, 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, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, 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 subheadings 7318.15.6080 or 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.
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 of Taiwan will be
subject to an additional ad valorem rate of duty of 20 percent. Your product falls 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 7318.15.6080 or 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)
James Forkan
Acting Director
National Commodity Specialist Division