The tariff classification of nut plate assemblies.

NY R01638 April 7, 2005 CLA-2-73:RR:NC:N1:118 R01638 CATEGORY: Classification TARIFF NO.: 7318.16.0085; 8302.30.3060 Mr. Dennis Forhart PricewaterhouseCoopers LLP 1420 Fifth Avenue, Suite 1900 Seattle, WA 98101 RE: The tariff classification of nut plate assemblies. Dear Mr. Forhart: In your letter, dated February 25, 2005, on behalf of your client, Freightliner® LLC, you requested a tariff classification ruling. The merchandise, nut plate assemblies, is described as follows: Part number A21-26032-000 is a steel nut plate assembly that affixes bumper struts to a vehicle’s frame. This nut plate is a steel threaded, hexagonal nut element combined with a rectangular, sheet steel base by means of a resistance projection weld. With a separate screw, it is used to fasten the bumper strut for each side of a bumper to a vehicle’s frame. Part number A18-33239-000 is a steel plate (bunk restraint) that affixes reinforcement channels to the rear skin of a sleeper cab. This nut plate is a steel threaded, hexagonal nut element combined with a rectangular base comprised of zinc plated steel. With a separate screw, it is used to fasten reinforcement channels to the rear skin of a sleeper cab. Part number A18-41658-000 is a steel assembly-plate (weld nut, fln cab mt, hys) that affixes a cab to a vehicle’s frame. It is part of a Hystec mount. This nut plate consists of 4 steel threaded, hexagonal nut elements combined linearly along a long, thin, rectangular steel base. With separate screws, the device fastens a vehicle cab to the bracket of a Hystec mount. The Hystec mount, in turn, joins the cab to the vehicle’s frame. Part number A22-41105-000 is an aluminum and steel assembly-nut plate (L/H, rear supt brkt). This nut plate functions as a support bracket, shoring up air deflecting fairing panels to the roof of a cab. The nut plate has an angular, aluminum base. Along its 2 base sides, holes and non-threaded, steel nut clinches are sequentially spaced. It is specifically shaped and used in conjunction with a rear support bracket to mount a fairing panel to the roof of a vehicle’s cab. The applicable subheading for part numbers A21-26032-000 (item 1) and A18-33239-000 (item 2) will be 7318.16.0085, Harmonized Tariff Schedule of the United States (HTS), 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: nuts: other: other. The general rate of duty will be free. The applicable subheading for part numbers A18-41658-000 (item 3) and A22-41105-000 (item 4) will be 8302.30.3060, HTS, which provides for base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar fixtures; castors with mountings of base metal; automatic door closers of base metal; and base metal parts thereof: other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof: of iron or steel, of aluminum or of zinc: other. The general rate of duty will be 2% ad valorem. Consideration was given to classifying part number A18-41658-000 within subheading 7318.16, HTS, as you suggested. However, unlike items 1 and 2, the assembly plate consists of four nut elements rather than a single nut attached to the base. Accordingly, your suggested classification is deemed inappropriate. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.). 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, contact National Import Specialist Kathy Campanelli at 646-733-3021. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division