CLA-2-73:OT:RR:NC:N5:121
Joann Martin
AFC Industries, Inc.
9030 Port Union Rd. Suite 100
West Chester, OH 45069
RE: The tariff classification of a carbon steel stud from Taiwan
Dear Ms. Martin:
In your letter dated September 18, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as an (M6-1.0 X 28) X (K70-2.46 X 12) External Torx
Drive Bolt CL. 8.8 with GMW3359-A Plating. It is a double end stud with a washer in the middle. One end
of the stud has thread forming threading, and the other has machine screw threading and an external Torx
drive. Its overall length is approximately 46 mm. It is made of low carbon steel with a special coating. This
component is used to mount the HVAC system in the interior of a motor vehicle through the firewall. The
thread forming side is fixed in place and provides a projection to which the HVAX system is attached.
The applicable subheading for the (M6-1.0 X 28) X (K70-2.46 X 12) External Torx Drive Bolt CL. 8.8 with
GMW3359-A Plating will be 7318.15.5090, Harmonized Tariff Schedule of the United States (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.
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 subheading 7318.15.5090, 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 subheading 7318.15.5090, HTSUS, listed above.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD) for
Carbon and Alloy Steel Threaded Rod from Taiwan. 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 (ITA) and are separate from tariff classification and origin rulings issued by
Customs and Border Protection (CBP). General information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division