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NY N020384

December 17, 2007



TARIFF NO.: 7318.24.0000

Mr. Thomas P. Sprowl
Nippon Express USA, Inc.
Chicago Air Cargo Branch
95 N. Division Street
Bensenville, IL 60106

RE: The tariff classification of steel retaining rings from Japan.

Dear Mr. Sprowl:

In your letter dated November 27, 2007, on behalf of Ochiai USA, Inc., you requested a tariff classification ruling. The samples which you submitted are being retained by this office.

You describe the samples as carbon steel retaining rings (Internal, External, Grip, E, C, U and K). You state that each retaining ring can be identified by their prefixes. The submitted samples were identified as RTW, ETW and STW. These conical and horseshoe shaped rings have openings on one side. They are primarily used as fasteners.

The applicable subheading for the retaining rings identified by prefixes RTW, STW, IRTW, ISTW, ETW and BETW will be 7318.24.0000, 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: cotters and cotter pins. The duty rate will be 3.8% ad valorem.

Consideration was given to your proposed classification of 7318.29.0000 HTSUS. In understanding the language of the HTSUS, the Harmonized Commodity Description and Coding System Explanatory Notes may be utilized. The Explanatory Notes (ENs), although not dispositive nor legally binding, provide a commentary on the scope of each heading of the HTSUS, and are the official interpretation of the Harmonized System at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The ENs of 73.18 describe one type of cotter as an item that can be in various shapes. Examples provided were horseshoe or conical. One function of a cotter is “for fitting into groves or slots cut round the shaft, spindle, etc.” Inasmuch as the retainer rings fit the 73.18 EN definition for cotters, classification within subheading 7318.29, HTSUS, would be inappropriate.

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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