CLA-2-73:OT:RR:NC:N5:121
Mohammad Shamim
Global Component Solution LLC
501 Silverside Road, Suite 105-5010
Wilmington, DE 19809
RE: The tariff classification of a Cylinder Head Stud Kit from India
Dear Mr. Shamim:
In your letter dated October 4, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as an Automotive Engine Head Stud Kit. The kit includes
steel studs with matching nuts and washers, a 20 ml grease pouch, allen/hex key, socket, nitrile gloves,
microfiber cloth, and an instruction sheet. The studs are composed of alloy steel with rolled threads on both
ends. The machining nuts and hardened washers are also made of alloy steel. The kits are used in the
automotive aftermarket for fastening engine cylinder heads to engine blocks. You note that the stud length,
thread length, and the number of studs, nuts, and washers will vary between kits depending on vehicle
application. You provided an example of a kit that contained 26 studs, with 26 matching nuts and washers.
You suggested this stud kit is classified under subheading 7318.15.5090, Harmonized Tariff Schedule of the
United States (HTSUS). We agree. The applicable subheading for the Automotive Engine Head Stud Kit 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.
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 August 27, 2025, Executive Order 14339 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. For products
covered by heading 9903.81.90 this additional duty applies to the non-steel content of the merchandise. At
the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e.
9903.01.84, in addition to subheading 7318.15.5090, HTSUS, listed above.
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 India will be
subject to an additional ad valorem rate of duty of 25 percent. For products covered by heading 9903.81.90,
this additional duty applies to the non-steel content of the merchandise. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.26, in addition to subheading
7318.15.5090, 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 studs imported from India may be subject to antidumping duties and 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
https://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
https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and
liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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