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 steel cable screw from China
Dear Ms. Martin:
In your letter dated November 4, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as a steel cable screw, part # X-99-10425/C-SPEC. This
fastener measures .25 inches in diameter and 3.25 inches in length. One end of the fastener is 1.05 inches
long and is unthreaded. The unthreaded end has an internal space that is .875 inches long in which to hold a
cable. The remaining length of the fastener has been threaded, with one side flattened so that the threading
does not form a helix around the shaft. You state this cable screw is part of an assembly that is used to install
bay windows and functions to fasten the cable to the cable clamp.
You suggested this item could be classified as a threaded article under subheading 7318.15.2095 or
7318.19.0000 or 7318.15.5090. We disagree, because this fastener is not considered threaded. A thread is a
ridge of uniform section in the form of a helix. The flattened side does not have ridges. Accordingly, a thread
has not been formed, and the fastener is considered to be non-threaded.
The applicable subheading for the steel cable screw, part # X-99-10425/C-SPEC will be 7318.29.0000,
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: Non-threaded articles: Other. The rate of duty will be 2.8%.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 10 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 7318.29.0000, HTSUS, listed above.
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 7318.29.0000, 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 China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 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 7318.29.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7318.29.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 7318.29.0000, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division