Image Search for HS Classification by TaichiKawazoe

Taichi Kawazoe

Search HScode from Customs Ruling Database

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HS classification is an important component to determining both import duty rates and if
products qualify for preferential tariff treatment under the many free trade agreements.

And also it’s important to classify HS code correctly but since HS classification system is a
black box, sometimes classification dichotomy occurs between Customs and Trader.

What happens if HS classification dichotomy or misclassification occurs?
Here are some consequences of  misclassification

  • Overpayment of duties
  • Missed opportunity to benefits from free trade agreement
  • Import may be subject to anti-dumping or countervailing duties
  • Alert to customs agents about deeper problems, which could lead to an audit
  • Unexpected customs clearance delays.

Based on my 10 years of experience as a Customs broker qualified by Japan Yokohama Customs. I can tell the method of HS classification.

In this article, you will learn

  1. How does HS classification dichotomy or misclassification occur?
  2. The best way to search for the appropriate HS code online.
  3. How to search the World Customs HS decision database to find reliable information.
  4. How to use item description, image, and basis of classification from Customs HS decision database

How HS Misclassification occurs?

Identifying the right HS code is sometimes easy but often difficult.
These examples demonstrate how difficult HS classification can be comparing simple examples and complex examples.

Example1. Wooden chair

Simple example

Source::European Union Website

This item is quite easy to classify. Nothing other than Upholstered wooden frame seats(HS:9401.61)

Complex example1

This item is hard to classify because this item can be classified both ways.

Choices are as follows:
1.Chair (HS:9401.80 -Other seats)
2.Hammocks (HS:6306.90 -Other camping goods)

 

Complex example2

Source::European Union Website

This item (set of table and chairs) is hard to classify because this item can be classified both ways.

Choices are as follows:
1.Wooden chair (HS:9401.69 -Seats)
2.Wooden table (HS:9603.60 -wooden furniture)

 

Example2. Watch

Simple example

Source::European Union Website

This item is quite easy to classify. Nothing other than Wristwatches(HS:9102)

 

Complex example1

Source: China customs

This item (Apple Watch) is hard to classify because it’s not just a watch, it has multiple functions.

Choices are as follows:

  • Telephone sets (HS:8517)
  • Sound recording or reproducing apparatus(HS:8519)
  • Video recording or reproducing apparatus(HS:8521)
  • Revolution counters,production counters,taximeters, odometers(HS:9029)
  • Measuring or checking instruments(HS:9031)
  • Wristwatches, pocketwatches and other watches(HS:9102)

 

Complex example2

Source::European Union Website

This item (set of Watch and Knive) is hard to classify because both are packed as a set product.

Choices are as follows:
1.wrist watches with mechanical display only(HS:9102.11)
2.Knives having other than fixed blades(HS:8211.93)

 

Example3. hand tool

Simple example1

Source::European Union Website

This item is quite easy to classify. Nothing other than Plier (HS:8203)

 

Simple example2

Source::European Union Website

This item is quite easy to classify. Nothing other than Wrenches (HS:8204)

 

Complex example

Source :Customs Bulletin

So-called “Locking pliers”, it has two functions of Plier and Wrenches

Choices are as follows:
1.Plier(HS:8203)
2.Wrenches(HS:8204)

With those examples above you may understand why HS misclassification occurs.
Some items are easy to classify, but some are not.

Customs’s opinion and Trader’s opinions are not always same, because there are
so many choices.

So is there any way to avoid HS misclassification?
The best way to avoid HS misclassification is to apply the Customs *Advance rulings
but the process is complicated and time-consuming.
Customs asks you so many questions regarding your items and require documents or
sample items when you apply for advance rulings.

If you deal with many items, applying for advance rulings is not always a good option.

*Advance ruling 
Importers and other relevant parties may make an inquiry to Customs regarding the
HS classification of the goods in advance of importation, which is called “Advance ruling.”
Advance ruling provides certainty on the Customs duty rate to be applied which is
issued in writing on the applicant’s written request.

Since applying for advance rulings is not always a good option, I recommend
Searching customs ruling database.

 

What is Customs Ruling Database

When Trader apply for advance ruling, Customs issues writing answer regarding
Trader’s item’s HS classification and opens it online.

There are more than one million classification records issued by customs all over the world which available on the internet.
They contain customs opinions based on a legal basis regarding how HS classification decision was made for each item individually and some items come with an image of the items.
If you usually struggle with HS classification, there is no way not using Customs Ruling
Database.

Here are some examples of Customs Ruling decision records available on the internet.

Item image
Issued Country Netherlands
Reference NLRTD-2013-002426
Issuing date 2013-11-11
Item name Hammock chair
Classified HS code 6306.90
Details & Customs Opinion A hammock chair with-as stated, include the following features and characteristics: – an up article in a rectangular shape – made from woven cotton – the two short sides of the fabric by means of braided cords attached to a wooden stick; – not shaped seat – a seating area with dimensions (L x W) 110 x 60-70 cm – a back section with dimensions (L x W) 110 x 70-80 cm – the hammock chair hanging on a wooden spreader with a length of 110 cm.De hammock chair is intended to be. attached to the ceiling, beam, or to a branch point The article takes the body shape of the person who sits in it. The hanging chair can be used both indoors and outdoors.

Classification is determined by General Rules 1 and 6 for the interpretation of the Combined Nomenclature, notes 7 to Section XI, Note 1 to Chapter 63, Regulation (EC) No 471/2002 of 15 March 2002 ( Official Journal L75) and the wording of CN codes 6306, 6306 90 and 6306 90 00.

 

Item image
Issued Country Germany
Reference DEBTI58717/18-1
Issuing date 2019-03-07
Item name ASSEMBLED FURNITURE
Classified HS code 9401.69
Details & Customs Opinion The product called “ASTRO chair” is a composite product consisting of an unpadded chair without armrests and a loose seat cushion. The chair is made of acacia wood and has a size of 60 x 59 x 89 cm (L x W x H). The goods are equipped with a backrest. The chair determines the character of the goods in terms of volume and importance for use. Two chairs are packed together as a set in a cardboard box. The goods shall be classified as ‘other than seats specified in heading 9402, not covered by subheadings (HS) 9401 10 to 9401 59, with a frame of wood, not upholstered’.

 

Item image
Issued Country China
Reference J2015-0015
Issuing date None
Item name Apple Watch
Classified HS code 8517.62
Details & Customs Opinion Apple Watch product design worn on the user’s wrist device that can directly communicate with the user’s iPhone. As the iPhone expansion device. The user can directly operate the device by Apple Watch the hardware and access many iPhone applications, achieve the iPhone function expansion: 1, processor; 2, the touch screen; 3, digital crown: by twisting the digital crown, be flexible and accurate screen zoom and scroll, crown and can be used as a button; 4, built-in speaker and microphone; 5 Linear actuator: to generate tactile feedback; 6, heart rate sensors: can help estimate the activity intensity, thus enhancing the overall situation with the measure calorie consumption level; 7, GPS, in order to achieve positioning and distance measurement; 8, the acceleration sensor control: to track physical activity throughout the day, and calculate motion steps to help measure calorie consumption; 9, a charging device; 10, the operating system. AC induction (eg transfer heartbeat); 10, by measuring heart rate, body sensing user activity, measured calories, and set moving target, and through collaboration with iPhone users view the activity log and view the progress of activities; 11, built Siri voice control This device; 12, through the built-APP realize calendar, Passbook (boarding passes, tickets, membership cards, coupon management software), edit iTune library, remote iPhone camera, stopwatch, timer, alarm clock, stocks, weather, and other functions; 13 , by third-party developers to develop applications to further implement other innovative features. When users buy Apple Watch equipment customers through the initial setup, the device is connected to the user’s iPhone immediately to implement the main features of the product include: 1, answer or reject calls; 2, by touching or dictation receive information; 3, receive, edit the message; 4, record voice memos; 5, the media access is stored in the iPhone (including pictures, music and video); 6 , function-based Global Positioning System (GPS) procedures; 7, set to the user’s iPhone; 8, graffiti screen and instantly share with other Apple Watch user; 9, by a linear actuator with a friend (others)

This product has a variety of functions, according to the General Rules of classification and 6.0, according to a communication device included in tariff codes 8517.62

 

Item image
Issued Country USA
Reference NY H87395
Issuing date 2002-02-12
Item name Quartz analog wristwatch and multi-function pocket knife
Classified HS code 9102.11 and 8211.93
Details & Customs Opinion The submitted wrist watch and multi-function pocket knife are classifiable under two separate headings or subheadings of the tariff. GRI 3 applies when goods are put up for sale collectively and are classifiable under two or more headings of the tariff. GRI 3(b) covers goods put up in sets for retail sale. Explanatory Note X to GRI 3(b) defines “goods put up in sets for retail sale”. Such goods: (a) consist of at least two different articles that are classifiable in different headings, (b) consist of products put up together to meet a particular need or carry out a specific activity, and (c) are put up in a manner suitable for sale directly to users without repacking. The submitted items fail, in our opinion, to constitute a set for tariff classification purposes. They meet the criteria of elements (a) and (c) above. The wrist watch and multi-function pocket knife do not consist of products put up together to meet a particular need or carry out a common specific activity. Having failed as a set in accordance with GRI 3(b) the wrist watch and multi-function pocket knife must be classified separately.

The applicable subheading for the wrist watch will be 9102.11.25, Harmonized Tariff Schedule of the United States (HTS)

The applicable subheading for the pocket knife will be 8211.93.0030, Harmonized Tariff Schedule of the United States (HTS)

 

Item image
Issued Country Poland
Reference PLBTIWIT-2019-000261
Issuing date 2019-03-19
Item name Wrench including Pliers
Classified HS code 8203.20
Details & Customs Opinion Pipe wrench made of chrome-vanadium steel, used to work under heavy load in plumbing. The wrench has a worm mechanism with a screw, regulating the opening of working jaws and a strong clamp, properly reinforced with long wrench arms. Solid “teeth” prevent the key from slipping on oval objects, pipes, valves or bolts. The jaws of the key are set at an angle of 45 degrees to the handle. The key length is 430 mm.

The tariff classification of the goods was determined on the basis of rules 1 and 6 of the General Rules for the Interpretation of the Combined Nomenclature, note 3 d of Section XV, note 1 (a) to Chapter 82 of the Common Customs Tariff and is consistent with the wording of heading 8203 WTC and TARIC code 8203 20 00 00 including pliers (including cutting pliers), pincers, tweezers and similar tools.

 

Here are HS code list of Automotive parts retrieved from Customs Ruling records.

Description hs code Image
Air conditioners 8415.20
Alternators 8511.50
Antennas 8529.10
Antifreeze 3820.00
Batteries 8507.10
Bearings, ball and/or roller 8482.40
Bearing housings and housed bearings 8483.20
Bearings, plain shaft type 8483.30
Belts of rubber 4010.35
Bodies (including cabs) 8707.10
Bolts & other fasteners of iron or steel 7318.29
Brake friction material of mineral substance 6813.81
Bushings (if plain shaft bearings) 8483.90
Cable, electrical (insulated) 8544.30
Cable, non-electrical, of steel 7312.10
Capacitors 8532.22
Camshafts & crankshafts 8483.10
Carpets, tufted 5703.20
Carpets, woven, not tufted or flocked 5702.42
Chain of iron or steel (including timing chain) 7315.11
Chain sprockets 8483.40
Chassis fitted with engine 8706.00
Cigarette lighters 9613.80
Circuit breakers 8536.10
Clamps of iron or steel for hoses 7326.20
Clutch friction material of mineral substance 6813.89
Compressors 8414.80
Control Boxes & panels 8537.10
Decals 4908.90
Defrosters & demisters 8512.40
Distributors & ignition/starting equipment 8511.40
Engines, diesel 8408.20
Engines, gasoline 8407.34
Engine parts, not provided for elsewhere 8409.91
Fans & Blowers 8414.59
Filters 8421.23
Fittings & mountings of base metal 8302.30
Fittings & mountings of plastic 3926.30
Fittings of iron or steel for pipes & tubes 7307.23
Flexible tubing of base metal 8307.10
Floor mats of rubber 4016.91
Pulleys 8483.50
Fuel injectors 8409.99
Punps for piston engines 8413.30
Fuses & similar electrical apparatus 8536.10
Gears 8483.40
Gauges 9026.20
Generators 8511.40
Handles & knobs of plastic 3926.30
Rubber parts and accessories 4016.99
Harnesses, electrical 8544.30
Heaters, electrical 8516.29
Horns & other sound or visual signaling equipment 8512.30
Hoses of rubber 4009.12
Hydraulic cylinders 8412.21
Integrated circuits 8542.31
Lamps 8539.32
Lenses of glass, signaling & optical 7014.00
Lighting equipment 8512.20
Locks & keys 8301.20
Magnets & electromagnetic articles 8505.20
Manuals & other printed matter 4901.10
Mirrors 7009.10
Motors, electric 8501.31
Motors, hydraulic or pneumatic 8412.39
Nameplates, signplates, etc.parts thereof of base metal 8310.00
Nuts & other fasteners of iron or steel 7318.16
Pins, cotter or dowel, & fasteners of iron or steel 7318.24
Printed circuit boards, blank 8534.00
Printed circuit boards, populated 8537.10
Vacuum pumps 8414.10
Pumps for liquids 8413.30
Radios, with tape & CD players 8527.91
Relays & similar electrical apparatus 8536.49
Resistors, electrical 8533.21
Rivets of iron or steel 7318.23
Rivets of base metal 8308.20
Screws & other fasteners of iron or steel 7318.15
Seals of plastic 3926.90
Seals of rubber 4016.93
Seats, cushions & other articles of furniture 9401.20
Crankshaft 8483.10
Sparkplugs 8511.10
Speedometers & odometers 9029.10
Springs of steel 7320.20
Springs of copper 7419.99
Studs & other fasteners of steel 7318.15
Switches & similar electrical apparatus 8536.50
Tape & CD players without a radio 8519.81
Thermostats, without valves 9032.10
Tires 4011.10
Tool (Hand tools) Kit 8206.00
STATIC CONVERTERS 8504.40
Turbochargers 8414.59
Universal joints 8483.60
Valves 8481.30
Washers & other fasteners of iron or steel 7318.22
Windshield window safety glass 7007.11
Windshield wipers 8512.40
Wrenches 8204.11

Retrieved from:European Union Website  , U.S. Customs and Border Protection

*When consulting the above list, please keep in mind that it is being offered for
reference purposes only and does not guarantee accuracy of classification.

 

The above data are retrieved from the Customs Ruling Database from all over the world.
If you usually struggle with HS classification, I highly recommend using Customs Ruling
Database.

But before using Customs Ruling Database to search HS code, it is necessary to understand the fundamentals of HS classification.

If you are not familiar with HS classification Please refer to the two below articles before searching from Customs Ruling Database otherwise you fell in a pit hole of HS classification.

The Fundamentals of HS classification

What is “General Rules of Interpretation (GRIs)”

Search HS code from Customs Ruling Database

Some customs provide their own Ruling database on the internet.
among them, two big databases are US customs “CROSS” and EU taxation and customs union “BTI Consultation”

US customs “CROSS”

CROSS

EU taxation and customs union “BTI Consultation”

BTI Consultation

The above two big databases contain more than 500 thousand ruling records.
If you look for a ruling record of a general trade item, most of the cases you would be able to find it from two of them.

So let’s take a look at how the search process works.

Suppose you are looking for HS code of “Wooden chair”, just type in the search bar “Wooden chair”.

Then you can see many ruling records of “Wooden chair” and HS codes.

When you need to see the details of the record, click referential NO.

Then you can see the details of the record.

Complex search

CROSS is a searchable database of CBP rulings that can be retrieved based on simple or complex search characteristics using keywords and Boolean operators.

Here are tips you can use when searching the database.

Keyword Input

Searches can be performed utilizing keywords, multiple keywords, phrases, and combinations of each.

  • Single keyword = doghouse

    Search results will include records with the keyword doghouse in the document.

  • Multiple keywords = dog house

    Search results will include records with both the keywords dog and house in the document.

  • Phrase = “dog house” enclosed in double quotes.

    Search results will include records with the exact phrase “dog house” in the document.

  • Search by tariff number

    – Simply enter 6204.43.4040 to retrieve rulings that contain this tariff number.

    – 6204.43.4040 6104.43.2020 6110.30.3055 will find rulings that reference all these tariff numbers.

  • Search by regulatory cite or statutory cite

    – Since there are a variety of ways these are expressed, the following techniques will yield favorable results: By breaking this cite into two phrases, “19 C.F.R.” “102.11(b)” will return rulings with 19 CFR § 102.11(b), 19 CFR 102.11(b), 19 C.F.R. 102.11(b)

    – The search phrase “19 U.S.C.” “1401(a)” or the search phrase “1401a” will return results where the search target may appear as 19 U.S.C. 1401(a)(b) or 19 U.S.C. 1401a(b). If parentheses are part of the phrase to be searched, they must be enclosed in quotes. Note that periods are used in the acronym, i.e., C.F.R. is used rather than CFR.

  • Search by ruling number

    – Enter 083536 to retrieve all rulings that reference that number.

    – Hint: to search for a specific ruling, make sure that the collection option is set to ALL and the date sort is set to descending.

    – Hint: if you are searching using a ruling number and do not get a hit by typing in the requested number, try adding a “W” in front of the number, for example W563543.

Punctuation marks such as the period (.), colon (:), semicolon (;), and comma (,) are ignored during a search.

 

BooleanOperators and Wildcards

Boolean operators are tools used to narrow your search results. They include AND, OR, and NEAR. The wildcard operator ( * ) is used to expand your search.

  • AND connecting two or more keywords or phrases will only match records containing all keywords or phrases. AND is the default operator when two or more keywords or phrases are entered without an operator.- dog AND “chew toy” is the equivalent of dog “chew toy”.- dog AND house is the equivalent of dog house.
  • AND NOT forbids the word or word phrase that follows it from appearing in the search result set.- red handbag AND NOT leather will find records containing words red and handbag and screens out records with the word leather.- dog AND NOT “chew toy” will return records with the word dog but not the phrase “chew toy”.- light emitting diode AND NOT “semi*” will find records containing words light, emitting and diode and screens out records with words starting with semi (such as semiconductor).- red handbag AND NOT leather AND NOT plastic AND NOT pink will find records with the words red and handbag but screens out records with the words leather or plastic or pink.
  • OR connecting two or more keywords or phrases, will match records containing any of the keywords or phrases.- dog OR “chew toy” returns records containing the keyword dog or the phrase “chew toy”.
  • A string of letters or digits followed by the wildcard (*) will match all records that contain keywords starting with the same pattern. This search type is especially useful when you don’t know the spelling of a particular keyword, or when you want to include all variants of a keyword in your search.- comput* returns records containing the words computer, computing, computation, etc…
  • Multiple operators can be used in a single search to create very specific result sets.- dog OR house AND wood matches records containing both the keywords house and wood, as well as records containing the keyword dog.

 

Correct Syntax

  • Two operators are not allowed next to each other.
  • No operator is allowed to start or end a query except the wildcard (*).
  • CROSS Search is not case sensitive and views mike, MIKE, and Mike as equivalents when searching.
  • Keywords can be any string of more than one letter and/or digits; but, cannot include non-alphanumeric characters such as: `~ ! @ # $ % ^ & and white space (tabs).

 

Image search

CROSS provides detailed information regarding each individual item, it must be a great source for determining HS code but sometimes information is so detailed that you could be overwhelmed and to be uncertain if that information really refers to the item you want to inquire.

Please be noted that CROSS mostly provides text information while EU taxation and customs union “BTI Consultation” provide many images.

If you are overwhelmed with CROSS’s tons of texts, I recommend you to search item images from “EU BTI Consultation” based on information retrieved from CROSS.

Let’s say you are looking for HS code of wooden chair at CROSS.

And when you are certain that wooden chiar’s HS code is 9401.61.4010.
Then copy the first 6 digits of the HS code.

Because the first 6 digits of the HS code is common anywhere in the world.
In order to see the item’s image from “EU BTI Consultation” you can only use the first 6 digits of the HS code to search.  The full digit of “9401.61.4010” is used only for the US.

Go to BTI Consultation and put 6 digits of “940161” in “Nomenclature code” form and search.
“Nomenclature code” is almost the same meaning as “HS code” or “HTS code”

In the result page, select the radio button of “Thumbnail View”.
Then you can see many kinds of item’s images based on the HS code you specified.

 

One more example.

Let’s say you are looking for HS code of “Ball bearing”, go to CROSS and type in the search bar “Ball bearing”.

Then you could expect that HS code of “Ball bearing” could be 8482.10 but not certain.
In order to see the Items’ example image, go to BTI Consultation and type 6 digits number of the HS code retrieved from Cross.

To make it clear, results should be sorted by “Number of images” and apply Thumbnail View.

Then you can be more certain that HS code of 8482.10 is appropriate for your targeting item with those images.

When it comes to HS classification you can get a clear view from those images.
Therefore you can be more certain than just classify with text information.

BTI Consultation is very powerful when it comes to search items image but it’s not a useful tool when it comes to text search because BTI Consultation contains the database of many EU countries and they consist of many languages.

In BTI Consultation database English is not a common language.
Some data has an English keyword but it’s not so detailed to be searched.

Therefore I recommend using Cross to search text-based information with English keyword to specify 6digits of HS code and using BTI Consultation to search image information to be more certain that the specified HS code is appropriate for your target item.

How to classify Bolt and Screw under HS code(HTS)

By

Even if a person knows the GRIs as well as they know their own social security number
and is aware of all the relevant legal and explanatory notes, classification is just
guesswork if invoices do not give complete and accurate descriptions of what is being
imported.

This is especially true when there is a lack of uniformity between Customs and
trade definitions.

Fasteners are a good case in point. Many shippers of automotive parts consider just
about any threaded fastener that can be used with a nut to be a “bolt.”

To Customs and the fastener industry, however, a threaded fastener which is used with
a nut may be a “screw” that has a duty rate which is far higher than a “bolt.”

Defenition of a Bolt and Screw

According to the Explanatory Notes for heading 7318

a bolt is designed to engage in a nut, whereas screws for metal are more usually
screwed into a hole tapped in the material to be fastened.

Screws are, therefore, generally threaded throughout their length, whereas bolts
usually have a part of the shank unthreaded.

Here are some examples of Bolt and Screw’s classification case.

Bolt：

Source : CBP
Reference : N090529
Date : 2010-01-15
HTS:7318.15.2065


Definition of a bolt:
a bolt is designed to engage in a nut, whereas screws for metal are more usually
screwed into a hole tapped in the material to be fastened.

 

Screw：

Source : CBP
Reference : NY H86189
Date : 2005-01-20
HTS:7318.15.8080


Definition of a Screw:
Screws are, therefore, generally threaded throughout their length, whereas bolts
usually have a part of the shank unthreaded.

These definitions are, however, just a few of the characteristics that need to be examined.
Both U.S. Customs and the fastener industry rely on a whole series of primary
and supplemental criteria to distinguish a bolt from a screw.

Source:Vehicles, Parts and Accessories Under the HTSUS(CBP)

It means there is a high possibility that HS (HTS) classification dichotomy occurs between
Customs and trading company when it comes to classifying “Bolt” and “Screw”.

 

Customs rulings for “Bolt” and “Screw”

Here are some other examples of customs rulings

Bolt HTS:7318.15.20

Source : CBP
Reference : NY H86191
Date : 2001-12-19
HTS:7318.15.2090

 

Source : CBP
Reference : NY F88287
Date : 2000-06-14
HTS:7318.15.2090

 

Source : CBP
Reference : NY D86443
Date : 1999-01-14
HTS:77318.15.2090

 

Source : CBP
Reference : NY G83591
Date : 2000-11-01
HTS:7318.15.20

 

Machine screws HTS:7318.15.40

Source : CBP
Reference : N126430
Date : 2010-10-14
HTS:7318.15.4000

Stud HTS:7318.15.50

Source : CBP
Reference : N034007
Date : 2008-07-31
HTS:7318.15.5060

 

Source : CBP
Reference : NY H86190
Date : 2001-12-19
HTS:7318.15.5060

 

Source : CBP
Reference : NY H86194
Date : 2001-12-19
HTS:7318.15.5060

 

Other (Screw) HS:7318.15.60

Source : CBP
Reference : NY H88741
Date : 2002-02-26
HTS:7318.15.60

Source : CBP
Reference : NY D88323
Date : 1999-02-23
HTS:7318.15.6060

 

Source : CBP
Reference : NY G87524
Date : 2001-03-12
HTS:7318.15.6060

 

Other (Screw) HS:7318.15.80

Source : CBP
Reference : NY G83167
Date : 2000-10-16
HTS:7318.15.8045

 

Complex classification case

Looks like a bolt but classified as Other(Screw)

Source : CBP
Reference : N034003
Date : 2008-07-31
HTS:7318.15.8065

Applicant of Ruling have described the item as a steel bolt that measures 6 mm in diameter.
It has a hex flange head and is 3½” long with a cone point.
It is used to connect the bushing to the front suspension lower/upper arm.

It looks like a bolt (HS:7318.15.20) but due to the use of this item , it classified as other(Screw)(HS:7318.15.8065)

Looks like a bolt but classified as Autoparts

Source : CBP
Reference : N057558
Date : 2009-5-5
HTS:8708.80

Pin Assembly is a bolt-shaped piece of zinc and chromate film-plated steel measuring approximately 5 inches in length by 1/2-inch in diameter. The piece is threaded for 21/2 inches and has a 3/4-inch bolt head. There is a 11/2-inch circular plate welded off-center to the top closest to the bolt head.

The plate is divided in half with the upper half having graduated marking cut into the metal.
This pin is designed to adjust the vehicle alignment allowing the vehicle to corner and brake more effectively.

Applicant of Ruling propose that Pin Assembly is classifiable in subheading 7318.15.
However, items that transmit motion in the sense that they perform adjustments are excluded from classification in EN heading 7318(A)(c).

Pin Assembly is “In use for the area where toe needs to be balanced.” The Road & Track Illustrated Automotive Dictionary defines “toe control” as ” … suspension geometry that
actively influences the amount of toe change at a wheel to enhance cornering or braking
ability.”

Therefor it was classified as motor vehicles : Suspension systems and parts thereof
(HS:8708.80)

 

Dichotomy between Czech and CBP

There was HS (HTS) classification dichotomy occur between Czech customs and CBP.
The subjected item was a screw that manually adjusts the height of the dipped beam
headlamp of the LED module of the headlamp.

Czech customs’s Decision

Source : European Commission
Reference : CZ40-0816-2017
Date : 2017-07-21
HTS:3926.90

General rules 1 and 6 for the interpretation of the Combined Nomenclature. Note 1 (g) to Section XVI Note 1 to Chapter 39. HS Explanatory Notes to heading 3926, point 6. Texts of codes 3926, 3926 90, 3926 90 97 of the Combined Nomenclature and Taric code 3926 90 97 90. To the applicant for the proposed code 8512 90 90 00 the goods in question can not be classified because they are not part of a headlamp which is indispensable for the function of the headlamp.

Since this ruling reffers Note 1 (g) to Section XVI Czech customs considered it as parts of general use. Therefore it’s classified as Other articles of plastics(HS:3926.90)

It means if this screw is made of steel , it would be classified as Other articles of steel
(HS:7318.15)

CBP’s decision

To the contrary of Czech Customs’s decision,CBP classified the screw as part of the motor vehicles.

Source : CBP
Reference : HQ 086396
Date : 1990-4-27
HTS:8708.99

The headlamp adjusting screw consists of a screw with a head socket (designed in the fashion as a Phillips screwdriver head) and a nylon housing.
The screw is made of metal and has dimensions of 1/4-28×2. The nylon housing is designed with an intake hole for the screw which is flanked on two sides by panels.
The panels assist in holding the screw at a fixed point.

The screw and nylon housing are fitted together permanently as one unit and are imported and sold as such. The unit is used to adjust the headlight beam of a passenger vehicle.

The subject merchandise is referred to as an adjusting screw, but is in fact a threaded mechanism that has as one of its principal components a dog-slotted screw.

The mechanism does not function as a conventional screw and nut combination does.
It operates to adjust the headlamp to the position needed. It functions as a part of the automobile to the same extent that the headlight itself does.

Consequently, the headlamp adjusting screw cannot be considered simply a screw or
similar to a screw-nut combination.

The Explanatory Notes (EN), although not dispositive, should be looked to for the proper interpretation of the HTSUSA. See 54 Fed. Reg. 35127, 35128 (August 23, 1989). Under EN 73.18(A)(c), it is explained that heading 7318 excludes threaded mechanisms

Therefore it’s classified as Parts and accessories of motor vehicles(HS:8708.99)

Subjected item was not the same but according to the explanation, they are almost the same products but two customs’s opinions are totally different.

It is not uncommon that this kind of HS (HTS) classification dichotomy occurs between
customs all over the world when it comes to Machine parts.

Therefore, before shipment, we need to survey HS classification very carefully especially “Parts”

How Bolt is classified under HScode

By

In order to reduce supply chain costs, proper HS Tariff Classification needs to be
taken when it comes to adopting CTC method under the FTA.

In this article, I’m going to introduce how “Bolt” is classified by the customs across the world.
Those classifying records are retrieved from each country’s Advanced ruling database.

Those information will be a great help to understand how customs might consider classifying.

German Customs case

Reference:DE11518 / 16-1
Classified HS code : 7318.15
Issuing date : 2017-7-20
Item name:THREADED SCREWS

Made of steel screws with an approximately semi-circular head with a flat and with a non-to-the-head thread (no thread-forming screw) and a blunt threaded end. The products are used as releasable fasteners in civil aircraft.
Total length: about 41.6 mm, thread diameter: about 9.1 mm. Picture see attachment. Such products belong to “TARIC code 7318 1595 90” as “other steel, threaded screws, with heads”.

Retrieved from:European Union Website

Usually, Bolt is considered as part of general use, therefore it’s classified to HS:7318.15
However, there are some exceptions that bolt could be considered as part of particular machine.

US customs(CBP) case

Reference:N057558
Classified HS code : 8708.80
Issuing date : 2009-5-5
Item name:bolt-shaped piece of zinc

It seems like part of general use, but CBP considered it as part of Automotive suspension systems because it’s in use for the “Toe control” area where “Toe” needs to be balanced that actively influences the amount of toe change at a wheel to enhance cornering or braking ability.

Therefore it’s classified as a part of Suspension systems HS:8708.80

Retrieved from:U.S. Customs and Border Protection

The difference of opinion between Czech and US Customs

Here are some classification case studies of Headlamp adjusting screw.
Two customs have different opinions for almost same kind of item.

Czech Customs case

Customs:Czech
Reference:CZ40-0816-2017
Classified HS code : 3926.90
Issuing date : 2017-07-21
Item name:THREADED SCREWS

Retrieved from:European Union Website

According to the declared data, it is a plastic screw that manually adjusts the height of the dipped beam headlamp of the LED module of the headlamp. Screw length: approx. 56 mm.

Based on General rules 1 and 6 for the interpretation of the Combined Nomenclature. Note 1 (g) to Section XVI Note 1 to Chapter 39, it’s considered as parts of general use, therefore, it’s classified to HS:3926.90

On the other hand, US customs have a different opinion on almost the same kind of item.

US Customs case

Customs:USA
Reference:HQ 086396
Classified HS code : 8708.99
Issuing date : 1990-4-27
Item name:Headlamp adjusting screw

<no image>

The headlamp adjusting screw consists of a screw with a head socket (designed in the fashion as a Phillips screwdriver head) and a nylon housing. The screw is made of metal and has dimensions of 1/4-28×2. The nylon housing is designed with an intake hole for the screw which is flanked on two sides by panels. The panels assist in holding the screw at a fixed point.

The screw and nylon housing are fitted together permanently as one unit and are imported and sold as such. The unit is used to adjust the headlight beam of a passenger vehicle. It is designed to fit all Cadillac automobile models from 1969 to 1981 model years, except for the Eldorado.

The subject merchandise is referred to as an adjusting screw, but is in fact a threaded mechanism that has as one of its principal components a dog-slotted screw.

The mechanism does not function as a conventional screw and nut combination does. It operates to adjust the headlamp to the position needed. It functions as a part of the automobile to the same extent that the headlight itself does. Consequently, the headlamp adjusting screw cannot be considered simply a screw or similar to a screw-nut combination.

The Explanatory Notes (EN), although not dispositive, should be looked to for the proper interpretation of the HTSUSA. See 54 Fed. Reg. 35127, 35128 (August 23, 1989).

Under *EN 73.18(A)(c), it is explained that heading 7318 excludes threaded mechanisms,
sometimes called screws, used to transmit motion, or otherwise act as an active part of a machine.

In the present case, the adjusting screw is indeed threaded similar to how a conventional screw is threaded. However, it transmits motion in the sense that it adjusts the headlamp, and therefore it is considered an active part of the automobile. Thus, we cannot classify the subject article under heading 7318, considering this exclusion.

*EN 73.18(A)(c)
Threaded mechanisms, sometimes called screws, used to transmit motion, or otherwise to act as an active part of a machine, (e.g., Archimedian screws; worm mechanisms and threaded shafts for presses; valve and cock closlng mechanisms, etc.) (Chapter 84). 

Conclusion

In my opinion, US customs tend to classify “parts” as part of a particular machine while other customs classify “parts” as parts of general use.

For example, US customs tend to classify “Computer mouse pad” as part of a computer machine while other customs classify it by material based method.

Hence it is essential to know the different opinions between the US and the other countries, when it comes to establishing a supply chain network.

How “Fuel injector” is classified under HS code

By

In this article, I’m going to introduce how “Fuel injector” is classified by customs across the world.
Those classifying records are retrieved from each country’s Advanced ruling database.

Those information will be a great help to understand how customs might consider classifying.
And also be a great help to reduce supply chain costs such as adopting CTC method under the FTA and smooth customs clearance procedures.

German Customs case

Reference:DE16784/12-1
Classified HS code : 8409.91
Issuing date : 2012-10-30

Item description:
High-pressure injector – from a specifically shaped valve housing with a multi-hole injector, injector nozzle needle, electrical connector and a connector for the fuel high-pressure line, with an injection pressure of 150/200 bar – for installation in an internal combustion engine with spark-ignition（petrol engine）, – for injecting under pressurized fuel into the combustion chamber.”Part suitable for use solely for internal combustion spark ignition engines of heading 8407″

 

 

 

 

 

 

 

 

Retrieved from: European Union Website

It’s classified to HS 8409.91 because it was considered that Injector is suitable for use solely for internal combustion spark ignition engines(HS:8407)

Japan Customs case

Reference:116005299
Classified HS code : 8409.91
Issuing date : 2016-11-11

Same as German customs It’s classified to HS 8409.91 because it was considered that Injector is suitable for use solely for internal combustion spark ignition engines(HS:8407)

Item description:
Structure of fuel injector used for automotive gasoline engine：Filter made of 5 kinds of main parts built into the main body（filter）Fuel filtering material located at fuel inlet（spring）When the injection port is fully closed. the needle valve is moved downward （solenoid coil）Electromagnetic coil（needle valve）Valve（nozzle plate）for opening and closing the injection port by suction force of the solenoid coil Injection port for atomizing fuel Characteristics：It consists of a cylindrical body.Size：Maximum diameter 15 mm. length 85 mm Function：A solenoid coil is energized by an ejection signal（electric signal）from the ECU and electromagnetic force is applied to the needle valve Is aspirated and rises and the injection port is opened by.applications boosted fuel is atomized from the injection hole of the nozzle plate injection：using packaging as a fuel injection system of an automobile engine：60 / box

This product is attached to the intake port of a piston type gasoline engine for automobile.receives an electric signal from the ECU.atomizes and injects the pressurized fuel. Because this product is recognized as a part to be used exclusively or mainly by the engine from its properties and functions etc..the tariff rate table part 16（b）.item 84.09 of the tariff rate table and item 84 According to the provision of paragraph 09.it is classified as above.

US Customs case

Reference:N272053
Classified HS code : 8481.80
Issuing date : January 28, 2016

To the contrary of German and Japanese customs decision, US customs classified Injector as Valves(HS:8481.80)

Item description:
The item under consideration is a high-pressure fuel injector, model number 35310-2GGA0. The fuel injector is attached to the fuel line of a motor vehicle and is designed to function as a valve. Once activated by the Electronic Control Unit, the solenoid armature and the valve needle incorporated into the fuel injector move upwards. This allows fuel to be sprayed through the valve seat openings and into the combustion chamber of a gasoline engine for brief periods of time. Once the fuel has been sprayed, the fuel injector’s compression spring returns the valve ball to the valve seat and seals the valve seat openings.

2015 Hyundai Sonata Throttle Body & Injector

Retrieved from:HyundaiPartsDeal.com

Importer insisted that “Fuel injector” should be classified as “Engine parts”(HS:8409) but
US Customs decided that “Fuel injector” should be classified as “Valves”(HS:8481) because US customs consider “Fuel injector” is nothing other than “Valves”

 

Conclusion

there is a difference in classification opinion between US customs and German, Japanese customs.
This kind of incident is not uncommon all over the world even though the 6digit HS code is a global common system.

It must be a smart way to check each country’s opinion from the Advanced ruling database before export or import cargo to avoid this kind of conflict.

How “Locking pliers” is classified under HS code

By

In order to reduce supply chain costs, proper HS Tariff Classification needs to be
taken when it comes to adopting CTC method under the FTA.

In this article, I’m going to introduce how “Locking pliers” is classified by the customs across the world.
Those classifying records are retrieved from each country’s Advanced ruling database.

Those information will be a great help to understand how customs might consider classifying.

Court case in the US

There was a conflict between importer and customs in court.
The issue was how to classify “Locking pliers” under HS code.

Importer insisted that “Locking pliers” should be classified as “Pliers”(HS:8203) but
Customs insisted that “Locking pliers” should be classified as “wrenches”(HS:8204)

In this case, the definition of “Pliers”(HS:8203) and “wrenches”(HS:8204) is important.
Here is an example classification record of “Pliers” and “wrenches”

Plier Classification record(HS:8203)

Pliers with specially shaped gripping jaws (working part). Made of chrome vanadium steel, fully hardened, powder-coated. Pliers have a slider for adjusting the jaw opening (several settings) and elongated handles, with double-PVC coated handles and a non-slip layer. Used for plumbing and general construction works.

Retrieved from:European Union Website

Wrenches Classification record(HS:8204)

Retrieved from:European Union Website

On the metric scale applied to the precision jaws.forged and hardened worm gear mechanism （forged and hardened).The key is made of chrome vanadium steel

 

The subject of the issue

The item below is the subject of the issue.

Retrieved from:Customs Bulletin

This “Locking pliers” has both essential characters of “Pliers” and “wrenches”.
It must be confusing how to classify.

Court decision

In the end, “Locking pliers” was classified as “Pliers”(HS:8203) not “wrenches”(HS:8204)

Below quoted from Customs Bulletin

Customs classified these tools as “wrenches” under heading 8204 of the Harmonized Tariff Schedule of the United States (“HTSUS”), and denied Importer’s protests to classify them as “pliers” under heading 8203,

The importer then filed suit in the Court of International Trade(CIT), challenging customs classification of the merchandise. The CIT denied customs motion for summary judgment that the tools are properly classified as wrenches under heading 8204, HTSUS, and granted Importer’s motion for summary judgment that the tools are properly classified as pliers under heading 8203, HTSUS.

At the CIT, Customs relied on dictionary definitions in support of its argument that a wrench is a “tool used to grasp an object and then turn or twist it (i.e., apply torque).”

The CIT found that although a wrench may be designed for a particular use, nothing about the tariff term for “wrenches” suggests a type of use such that the court should declare the tariff term one controlled by use.

Therefore, the CIT concluded that “wrench” is an eo nomine term, not one controlled by use. It rejected Customs’s proffered definition and defined a wrench referring only to its physical attributes as a “hand tool that has a head with jaws or socks having surfaces adapted to snugly or exactly fit and engage the head of a fastener (as a bolt-head or nut) and a singular handle with which to leverage hand pressure to turn the fastener without damaging the fastener’s head.”

The CIT held that the products under consideration were not wrenches because they incorporate two handles and jaws that do not necessarily snugly fit the head of a fastener.

Auto parts HS code list of 100 with sample images

By

Vehicles are provided for in Chapter 87 of the HS tariff code.
Many of the parts and accessories for such vehicles are also classifiable in Chapter 87, but there are many exceptions.
In this article, you can see auto parts HScode list of 100 to make it easy to classify.

Auto parts under HScode

Description hs code Image
Air conditioners 8415.20
Alternators 8511.50
Antennas 8529.10
Antifreeze 3820.00
Batteries 8507.10
Bearings, ball and/or roller 8482.40
Bearing housings and housed bearings 8483.20
Bearings, plain shaft type 8483.30
Belts of rubber 4010.35
Bodies (including cabs) 8707.10
Bolts & other fasteners of iron or steel 7318.29
Brake friction material of mineral substance 6813.81
Bushings (if plain shaft bearings) 8483.90
Cable, electrical (insulated) 8544.30
Cable, non-electrical, of steel 7312.10
Capacitors 8532.22
Camshafts & crankshafts 8483.10
Carpets, tufted 5703.20
Carpets, woven, not tufted or flocked 5702.42
Chain of iron or steel (including timing chain) 7315.11
Chain sprockets 8483.40
Chassis fitted with engine 8706.00
Cigarette lighters 9613.80
Circuit breakers 8536.10
Clamps of iron or steel for hoses 7326.20
Clutch friction material of mineral substance 6813.89
Compressors 8414.80
Control Boxes & panels 8537.10
Decals 4908.90
Defrosters & demisters 8512.40
Distributors & ignition/starting equipment 8511.40
Engines, diesel 8408.20
Engines, gasoline 8407.34
Engine parts, not provided for elsewhere 8409.91
Fans & Blowers 8414.59
Filters 8421.23
Fittings & mountings of base metal 8302.30
Fittings & mountings of plastic 3926.30
Fittings of iron or steel for pipes & tubes 7307.23
Flexible tubing of base metal 8307.10
Floor mats of rubber 4016.91
Pulleys 8483.50
Fuel injectors 8409.99
Punps for piston engines 8413.30
Fuses & similar electrical apparatus 8536.10
Gears 8483.40
Gauges 9026.20
Generators 8511.40
Handles & knobs of plastic 3926.30
Rubber parts and accessories 4016.99
Harnesses, electrical 8544.30
Heaters, electrical 8516.29
Horns & other sound or visual signaling equipment 8512.30
Hoses of rubber 4009.12
Hydraulic cylinders 8412.21
Integrated circuits 8542.31
Lamps 8539.32
Lenses of glass, signaling & optical 7014.00
Lighting equipment 8512.20
Locks & keys 8301.20
Magnets & electromagnetic articles 8505.20
Manuals & other printed matter 4901.10
Mirrors 7009.10
Motors, electric 8501.31
Motors, hydraulic or pneumatic 8412.39
Nameplates, signplates, etc.parts thereof of base metal 8310.00
Nuts & other fasteners of iron or steel 7318.16
Pins, cotter or dowel, & fasteners of iron or steel 7318.24
Printed circuit boards, blank 8534.00
Printed circuit boards, populated 8537.10
Vacuum pumps 8414.10
Pumps for liquids 8413.30
Radios, with tape & CD players 8527.91
Relays & similar electrical apparatus 8536.49
Resistors, electrical 8533.21
Rivets of iron or steel 7318.23
Rivets of base metal 8308.20
Screws & other fasteners of iron or steel 7318.15
Seals of plastic 3926.90
Seals of rubber 4016.93
Seats, cushions & other articles of furniture 9401.20
Crankshaft 8483.10
Sparkplugs 8511.10
Speedometers & odometers 9029.10
Springs of steel 7320.20
Springs of copper 7419.99
Studs & other fasteners of steel 7318.15
Switches & similar electrical apparatus 8536.50
Tape & CD players without a radio 8519.81
Thermostats, without valves 9032.10
Tires 4011.10
Tool (Hand tools) Kit 8206.00
STATIC CONVERTERS 8504.40
Turbochargers 8414.59
Universal joints 8483.60
Valves 8481.30
Washers & other fasteners of iron or steel 7318.22
Windshield window safety glass 7007.11
Windshield wipers 8512.40
Wrenches 8204.11

Retrieved from:European Union Website  , U.S. Customs and Border Protection

*When consulting the above list, please keep in mind that it is being offered for
reference purposes only and does not guarantee accuracy of classification.

THE HEADINGS OF CHAPTER 87

Altogether there are sixteen different four-digit tariff headings or main groupings in Chapter 87. These are:

For those concerned with things “automotive,” the principal headings of interest are 8701-8708. Heading 8701 covers all tractors except those of heading 8709 (the term “tractors” is defined in Note 2 to Chapter 87 as “vehicles constructed essentially for hauling or pushing another vehicle, appliance or load” and includes, in subheading 8701.20, road tractors which pull semi-trailers). Heading 8702 covers motor buses and coaches.

Heading 8703 covers vehicles for transporting people, like cars.
Heading 8704 covers vehicles for transporting goods.
Heading 8705 covers special purpose motor vehicles other than those principally designed for the transport of persons or goods (e.g. garbage trucks, even those with compactors, would go in 8704 if their principal function is to transport trash).

It does not, however, cover self-propelled wheeled machines in which the chassis and the working machine are specially designed for each other and form an integral mechanical unit (road graders go in Ch. 84).

Heading 8706 covers chassis with engines for all the foregoing vehicles, but does not include chassis fitted with engines and cabs (they go in headings 8702-8704).
Heading 8707 covers bodies, including cabs, for the foregoing vehicles. And lastly, heading 8708 covers parts and accessories for these motor vehicles. In general, articles are “parts” if they cannot be used on their own but must be combined with other articles to form goods capable of fulfilling an intended function; “accessories” are articles that are not needed to enable the goods with which they are used to fulfill their intended function.

Pretty simple stuff, right? Wrong! As anyone who has followed the ups and downs of
sport utility vehicle classification over the years knows, it’s not so easy sometimes to
determine which heading a given article should have for tariff purposes. If a multipurpose vehicle is suitable for carrying both passengers and cargo, and has characteristics associated with both cars and trucks, should it go in 8703 or 8704? U. S. Customs for many years considered two-door sport utility vehicles like the Nissan Pathfinder to be motor vehicles for the transport of goods, which made them subject to a 25% duty. This position was eventually overturned by the courts, however, and such vehicles are now classifiable with motor cars and other motor vehicles principally designed for the transport of persons.

What items excluded from Chapter 87

There are General Rules of Interpretation (GRIs for short) that govern tariff classification.

For another, the legal notes to Section XVII, which includes Chapter 87, exclude many items that would seemingly go there.

Section XVII note2

The expressions “parts” and “parts and accessories” do not apply to the following articles、whether or not they are identifiable as for the goods of this Section：

（a） Joints、washers or the like of any material（classified according to their constituent material or in heading 84.84）or other articles of vulcanised rubber other than hard rubber（heading 40.16）;

（b） Parts of general use、as defined in Note 2 to Section XV、of base metal（Section XV）、or similar goods of plastics（Chapter 39）;

（c） Articles of Chapter 82（tools）;

（d） Articles of heading 83.06;

（e） Machines or apparatus of headings 84.01 to 84.79、or parts thereof、other than the radiators for the articles of this Section; articles of heading 84.81 or 84.82 or、provided they constitute integral parts of engines or motors、articles of heading 84.83;

（f） Electrical machinery or equipment（Chapter 85）;

（g） Articles of Chapter 90;

（h） Articles of Chapter 91;

（ij） Arms（Chapter 93）;

（k） Lamps or lighting fittings of heading 94.05; or

（l） Brushes of a kind used as parts of vehicles（heading 96.03）

Before getting into specifics, however, a clarification of what constitutes a “vehicle” would appear to be in order. The term “vehicle” is derived from the Latin word “vehiculum.”

It means a carriage or conveyance. The type of vehicles which go in Chapter 87 are, for the most part, those whose main function is to transport people or things from one place to another (three exceptions: tractors, special purpose motor vehicles and armored fighting vehicles).

Mobile machines, in which a propelling base forms an integral part of a machine designed for handling, excavating, etc.,are not considered, for tariff purposes, to be
vehicles of Chapter 87. Fork lift trucks, excavators, bulldozers, front-end loaders and the like are classifiable in Chapter 84 along with other “Machinery and Mechanical
Appliances.”

PARTS AND ACCESSORIES

As complicated as vehicle classification can be, however, it’s usually much easier than
trying to classify parts and accessories for them. For, while heading 8708 reads “Parts
and accessories of the motor vehicles of headings 8701 to 8705,” it does not cover all
such parts.

In order for motor vehicle parts or accessories to be classifiable under heading 8708, they must satisfy all three of the following conditions:

  1. They must be identifiable as being suitable for use solely or principally with
    motor vehicles of headings 8701-8705.
  2. They must not be excluded by Section XVII, Note 2.
  3. They must not be more specifically provided for elsewhere in the HTSUS.

As we said in the beginning, classification is governed by six GRIs. Of these, the most
important is the first one. GRI 1 provides that “classification shall be determined according to the terms of the headings and any relative section or chapter notes.”

If you can classify goods using it, there is no need to refer to the others which follow in sequential order.

Since the provisions for motor vehicles in Chapter 87 are incorporated in Section XVII of the HTSUS, the legal notes to that section are particularly important. It is from there, in fact, that the first two conditions given above are derived.

The third condition is based on GRI 3(a) which states that when goods are classifiable under two or more headings, theheading which provides the most specific description shall be preferred. The Additional U.S. Rules of Interpretation, which follow the GRIs in the HTSUS, reinforce this principle by providing in paragraph 1(c) that “a provision for parts of an article covers products solely or principally used as a part of such articles, but a provision for “parts” or “parts and accessories” shall not prevail over a specific provision for such part or accessory.” Unless one is dealing with parts which have multiple applications on motor vehicles of Chapter 87 and machines of Chapter 84, the first of these conditions is not likely to be a problem.

Most parts used on cars and trucks are, after all, usually used only on motor vehicles–not other machines. The second condition, however, is another story.
The exclusions listed in the notes to Section XVII are many and, to the untrained observer, easy to overlook. Among other things, these notes exclude all joints, washers or the like of any material; articles of vulcanized rubber other than hard rubber; parts of general use, as defined in Note 2 to Section XV (whether made of base metal or plastic) and gears and other transmission equipment of heading 8483 which are integral components of engines or motors (clutches, gears, torque converters. Other vehicle transmission equipment of heading 8483 which is not an integral component of engines or motors goes in heading 8708).

In a similar vein, one must also keep in mind that some automotive parts and accessories which are specifically provided for in other chapters may still be classifiable in heading 8708 if they are excluded by other section or chapter notes.

One not only has to be aware of Section XVII’s notes, but those of other sections and chapters that might apply.

Chapter 39, for example, has a note which excludes parts of vehicles of Section XVII.
Consequently, a plastic hose or tube which is a finished auto part would go under 8708
rather than 3917 which is a specific provision.

It is also important to keep in mind that legal notes in one place may be offset in another section or chapter. The aforementioned Chapter 39 legal note excluding parts of Section XVII vehicles does not mean that plastic gaskets or plastic mountings and fittings for doors, windows and coachwork go in 8708. Such articles are excluded from Chapter 87 by the exclusionary notes to Section XVII which cover “joints, washers or the like of any material” and “parts of general use.”

Parts Of General Use

The term “parts of general use,” incidentally, is one that is often misunderstood by
importers and exporters who come across the phrase. Contrary to what a lot of people
think, it does not mean “parts which have multiple applications” or “parts which have no principal use.” Made-to-order parts that are suitable for only one particular application and are not good for anything else, can still be “parts of general use.”

The term has a very precise legal definition which may be found in Note 2 to Section XV. For purposes of Section XVII, it means the following types of articles whether made of iron or steel, some other base metal, or plastic:

In this definition, many HS codes are scattered throughout the definition.
Hence still unclear what “parts of general use” mean.

Below is an image list of “parts of general use” for each HS code defined in Explanatory Note Section XV note 2.

HS7307: Tube or pipe fittings

(for example, couplings, elbows, sleeves), of iron or steel:

 

HS7312: Stranded wire, ropes,

cables, plaited bands, slings and the like, of iron or steel, not electrically insulated:

HS7315: Chain and parts thereof, of iron or steel:

HS7317: Nails, tacks, drawing pins, corrugated nails, staples

HS7318: Screws, bolts, nuts, coach screws,

screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel

 

HS: 7318.21: Spring washers and other lock washers

HS8301: Padlocks and locks

HS8302: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:


 

 

HS8308: Clasps, frames with clasps,

buckles, buckle-clasps, hooks, eyes, eyelets and the like, of base metal, of a kind used for clothing or clothing accessories, footwear, jewelry, wrist watches, books, awnings, leather goods, travel goods or saddlery or for other made up articles; tubular or bifurcated rivets, of base metal; beads and spangles, of base metal:

HS8310: Sign plates, name plates,

address plates and similar plates, numbers, letters and other symbols, and parts thereof, of base metal, excluding those of heading 9405

 

HS:8306 Bells, gongs and the like,

nonelectric, of base metal; statuettes and other ornaments, of base metal; photograph, picture or similar frames, of base metal; mirrors of base metal; and base metal parts thereof:

What is Fittings for Coachwork(plastic autoparts) HS:392630

When it comes to classifying automotive parts made of plastic,
one of the options is HS:392630 (Fittings for furniture, coachwork, or the like:)

I wonder why HS tariff used the terms of “coachwork”??
It should be “automotive”??

And also many people may wonder what kind of items are classified as “Fittings for Coachwork”?
So I retrieved items which are classified as “Fittings for Coachwork”(HS:3926.30)
from many customs ruling database.

Below is the list of the items classified as “Fittings for Coachwork”(HS:3926.30)

Examples of “Fittings for Coachwork”(HS:3926.30)


door handle
Czech Customs:CZBTI37/086941/2018-580000-04/01


cable guide
German customs:DE239/17-1

 


cable guide
German customs:DE686/17-1

 


cover  mounted behind the interior trim of motor vehicle door
German customs:DE966/17-1


panel for window frames
German customs:DE4899/16-1

 

 


belt deflector
German customs:DE4949/17-1

 


cover assembly hole are directly and permanently mounted on motor vehicles behind the inner panel on the body of the left door
German customs:DE8666/17-1

 

 


entry bar made of molded plastic
German customs:DE14779/16-1

 


mounting bracket used to hold control units
German customs:DEBTI1836/18-1

 


The approximately 32.4 x 24.4 x 10.4 cm shaped product is essentially eleven Recesses for relay socket and plug couplings and a large main compartment for a control unit provided
German customs:DEBTI3532/18-1

 


door handle
German customs:DEBTI13185/18-1

 


universal mount for example, Mobile phones or iPods with two self-locking clamping devices
German customs:DEHH/15/09-1

 


door handle
German customs:DEHH/1118/05-1

 


Plates and emblems for tourist cars
spain customs:ESBTI2017SOL0000000000749

 


automotive plastic wheel attachment
French customs:FR-E4-2006-002796

 


Chrome-plated plastic edging for the power window block mounted on the car door next to the driver
Latvia customs:LVBTI2019-91

 


Interior door handle
Slovakia customs:SK13409/09/5219/28

 

Plastic but not “Fittings for Coachwork”(goes to 8708)

Even though the items below are made of plastic, they are essential parts of automobiles and satisfy all three of the following conditions:(Section XVII GENERAL(III))

(a) They must not be excluded by the terms of Note 2 to this Section
(b) They must be suitable for use solely or principally with the articles of Chapters 86 to
88
(c) They must not be more specifically included elsewhere in the Nomenclature

Therefore they are not classified as HS:3926.30


The plastic blower for cars
Slovakia customs:SK12536/16/02


Parts of a steering column
German customs(DE):DE892/17-1

 


CONSOLE
United Kingdom customs:GB501958157

Glove box
German customs:DE4894-16-1

 


Reflector for motor vehicles
Belgium customs:BED.T.251.513


DOOR COMPARTMENT (ASHTRAY)
Italy customs:ITBTIIT-2017-0430M-314100

Retrieved from:European Union Website

 

“Fittings for Coachwork” is a vague term. I looked for the definition of it but could not find it.

Here is just my opinion to differ from them.
plastic parts for automotive which work directly for the automotive mechanism goes to 8708.
On the contrary plastic parts for automotive which works as Accessories, like connecting, attach, fix something to the place, etc goes to 3926.30(fittings for coachwork)

Since there is no clear definition for it, I determine them by items picture obtaining from the customs ruling database.

Please refer to the above pictures to see the difference between auto parts made of plastic 3926 and 8708.

GOOD INVOICING IS ESSENTIAL

Even if a person knows the GRIs as well as they know their own social security number
and is aware of all the relevant legal and explanatory notes, classification is just guesswork if invoices do not give complete and accurate descriptions of what is being
imported.

This is especially true when there is a lack of uniformity between Customs and trade definitions. Fasteners are a good case in point. Many shippers of automotive parts
consider just about any threaded fastener that can be used with a nut to be a “bolt.”

To Customs and the fastener industry, however, a threaded fastener which is used with a nut may be a “screw” that has a duty rate which is more than twelve times higher! According to the Explanatory Notes for heading 7318, a bolt is designed to engage in a nut, whereas screws for metal are more usually screwed into a hole tapped in the material to be fastened.

Screws are, therefore, generally threaded throughout their length, whereas bolts
usually have a part of the shank unthreaded. These are, however, just a few of the
characteristics that need to be examined.

Both U.S. Customs and the fastener industry rely on a whole series of primary and supplemental criteria to distinguish a bolt from a screw.

Some other terms for auto parts that can be a problem because they are so vague are
“actuator,” “bearing,” “gasket,” “seal,” “solenoid,” “valve,” and “washer.” Such descriptions by themselves are too broad to classify the goods properly and there is more than one classification and duty rate which could apply.

Without more specific information, Customs officers may assume the classification with the highest duty rate is the right one–to the detriment of the party paying the duties. Needless to say, it is to the shipper and importer’s advantage to make sure such articles are described fully enough to avoid further inquiries or unwarranted additional duty assessments from Customs.