The tariff classification of a steel compression limiter from China

N362924
August 4, 2026
CLA-2-73:OT:RR:NC:N5:121
CATEGORY: Classification
TARIFF NO.: 7318.29.0000
David Mize US Farathane LLC 2700 High Meadow Circle Macomb, MI 48044 RE: The tariff classification of a steel compression limiter from China Dear Mr. Mize: In your letter dated July 7, 2026, you requested a tariff classification ruling. Photographs and descriptions of the merchandise were included in your inquiry. The article under consideration is described as a compression limiter, part number PINSS093F. It is a cylindrical steel component with an oval inner hole and a knurled outer edge that is used in conjunction with a bolt or screw as part of a fastening system. This compression limiter is designed for and used exclusively on an alternator splash shield cover for a specific motor vehicle and functions as a sleeve or spacer. It is pressed into place in the plastic cover and secured by a flanged hex head bolt. The bolt head clamps against the compression limiter instead of directly on the plastic. When the sleeve is fully compressed between the mounting surfaces, tightening stops increasing the load on the plastic, thereby protecting the plastic from being crushed, creeping over time, or cracking while maintaining consistent clamp force. You state that its primary purpose is to: 1) limit the compression of plastic or composite materials when a fastener is tightened; 2) maintain consistent clamping force within an assembly; and 3) prevent deformation or damage to the surrounding material. You suggested that this item could be classified under subheading 8708.29.51.60, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: 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 compression limiter meets the definition of a base metal fastener and is more specifically provided for in heading 7318, HTSUS. As such, it is considered a “part of general use” per Note 2(a) to Section XV and is precluded from classification in heading 8708, HTSUS. The applicable subheading for the compression limiter will be 7318.29.0000, 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 general rate of duty will be 2.8%. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 P. Forkan Director National Commodity Specialist Division