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HQ 954144

August 18, 1993

CLA-2 CO:R:C:M 954144 LTO


TARIFF NO.: 7508.00.50

Mr. James F. Carroll
J.M. Rodgers Co., Inc.
90 West Street, Room 1510
New York, New York 10006

RE: Tie Rods; Reconsideration of PC 877340; "parts of general use"; section XV, note 2; section XVI, note 1(g); heading 7318; EN 73.18

Dear Mr. Carroll:

This is in response to your letter of May 10, 1993, on behalf of North Bridge, Inc., requesting reconsideration of PC 877340, dated September 11, 1992, concerning the classification of tie rods under the Harmonized Tariff Schedule of the United States (HTSUS).


The articles in question are tie rods, which are used exclusively with jet aircraft engines. Tie rods are structural rods which tie the compressor and turbine assemblies in an engine together. They may be internally or externally threaded on both ends or may have a head on one end. Tie rods resemble bolts but are produced from materials of greater tensile strength to withstand more rotational shear stress than most bolts require. In PC 877340, the District Director of Customs in Ogdensburg, New York, advised you that these articles were classified under subheading 7508.00.50, HTSUS, which provides for other articles of nickel.


Whether the tie rods are classifiable as aircraft parts under heading 8411, HTSUS.


The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states in pertinent part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ."

The subheadings at issue are as follows:

7508.00.50 Other articles of nickel:

8411.91.90 Turbojets, turbopropellers and other gas turbines, and parts thereof:
Of turbojets or turbopropellers:

You contend that the tie rods are more specifically provided for under subheading 8411.91.90, HTSUS. However, heading 8411, HTSUS, falls within section XVI. Note 1(g) to section XVI states that this section does not cover "[p]arts of general use, as defined in note 2 to section XV, of base metal (section XV) . . . ." Therefore, it is necessary to determine whether the tie rods are "parts of general use," of base metal.

Note 2(a) to section XV states that the following articles are parts of general use: "[a]rticles of heading 7307, 7312, 7315, 7317 or 7318 and similar articles of other base metals [underlining added]." Heading 7318, HTSUS, provides for various types of fasteners, including bolts of iron or steel. Thus, if we determine that the nickel tie rods are similar to the bolts of iron or steel of heading 7318, HTSUS, the tie rods cannot be classified under heading 8411, HTSUS.

The Harmonized Commodity Description and Coding System Explanatory Notes (EN) constitute the Customs Co-operation Council's official interpretation of the Harmonized System. While not legally binding, the ENs provide a commentary on the scope of each heading of the Harmonized System, and are generally indicative of the proper interpretation of these headings.

EN 73.18, pg. 1028, with regard to the classification of screws, bolts and nuts, provides as follows:

Bolts and screws for metal are cylindrical in shape,
with a close and only slightly inclined thread; they are rarely pointed, and may have slotted heads or heads adapted for tightening with a spanner or they may be recessed. A bolt is designed to engage a nut, whereas screws for metal are more usually screwed into a hole tapped in the material to be fastened and are therefore generally threaded throughout their length whereas bolts usually have a part of the shank unthreaded.

The heading includes all types of fastening bolts and metal screws regardless of shape and use . . . .

You provided a description of the articles in question from the Pratt & Whitney aircraft manual. The manual states that tie rods function as and resemble bolts but are produced from materials of greater tensile strength. Based on this description, we believe that the tie rods are similar to bolts of iron or steel, and are "parts of general use," as that term is defined by note 2(a) to section XV. Therefore, the tie rods are excluded from section XVI and heading 8411, HTSUS.

EN 75.08, pg. 1059, states that heading 7508, HTSUS, covers all articles of nickel, not more specifically covered elsewhere in the tariff schedule, including nickel bolts. Because the tie rods are not covered by a more specific provision, they are classifiable under heading 7508, HTSUS, specifically under subheading 7508.00.50, HTSUS.


The tie rods are classifiable under subheading 7508.00.50, HTSUS, which provides for other articles of nickel. The corresponding rate of duty for articles of this subheading is 5.5% ad valorem.

PC 877340, dated September 11, 1992, is affirmed.


John Durant, Director

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