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NY R05154

November 14, 2006

CLA-2-73:RR:E:NC:N1:118 R05154


TARIFF NO.: 7318.15.8082; 8483.90.5000

Mr. Joshua Bloomfield
Rolls-Royce North America, Inc.
2001 S. Tibbs Ave.
Indianapolis, IN 46241

RE: The tariff classification of a “Double Hex Head Bolt” and a “Cup Washer” from Great Britain.

Dear Mr. Bloomfield:

In your letter dated October 31, 2006, you requested a tariff classification ruling for two items used in a gas turbine engine.

The first item, part number AS21518, you described as a stainless steel double hex head bolt designed for use in a gas turbine engine. It is used in various places throughout the engine (i.e. oil tank, drive generator). The diameter of the shank is 6.25mm and the diameter of the threads is 6.35mm. The article is partially threaded and can accommodate a nut.

The second item, part number KC2427, you described as a stainless steel cup washer used in the gearbox of a gas turbine engine. The article is a 4.1mm round disc with a hole in the center. There are two tabs machined on the inside perimeter of the disc and the outer edge of the cup washer fits into the recesses on the nut, locking them together. This keeps the nut from loosening while in service. The thread on the gear shaft has two longitudinal grooves cut into it, this allows the cup washer to slide over the thread but it is unable to rotate.

The applicable subheading for the double hex head bolt will be 7318.15.8082, 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: threaded articles: other screws and bolts, whether or not with their nuts or washers: other: having shanks or threads with a diameter of 6 mm or more: other: other: other: of stainless steel. The duty rate will be 8.5% ad valorem.

Consideration was given to classifying this article under 7318.15.2061, HTSUS, as you have suggested. However, this article would not be considered a bolt since it is capable of being turned during assembly and does not have to be assembled with a nut to perform its intended function. Based upon supplementary criteria of ASME B18.2.1, this product is classified as a screw.

The applicable subheading for the cup washer will be 8483.90.5000 HTSUS, which provides for parts of gearing, gear boxes and other speed changers. The rate of duty will be 2.5% ad valorem.

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 on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Kathy Campanelli at 646-733-3021.


Robert B. Swierupski

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