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NY L81925




January 20, 2005

CLA-2-73:RR:NC:N1:118 L81925

CATEGORY: CLASSIFICATION

TARIFF NO.: 7318.15.2095; 7318.15.8085

Mr. Robert Resetar
Porsche Cars North America, Inc.
980 Hammond Drive, Suite 1000
Atlanta, GA 30328

RE: The tariff classification of connecting rod bolts from Germany.

Dear Mr. Resetar:

In your letter, dated January 5, 2005, you requested a tariff classification ruling. We are returning your samples as you have requested.

The merchandise, comprised of connecting rod bolts utilized in the automotive industry, is described as follows:

Connecting rod bolt, part 996 103 176 70, is a steel bolt measuring 69 mm in length, including the head, and having a diameter of 9 mm at the threads. The bolt is threaded on only half the length. The other half, towards the head, has circular protrusions. The head of the bolt, although mostly round, has an 8 mm flat area. This bolt slides through holes in the connecting rod and is secured with a steel torx nut, part number 993 103 174 02. The bolt is prevented from rotating by its uniquely shaped head, which has a corresponding shape cast into the connecting rod. Connecting rod bolt, part 997 103 115 01, is a steel bolt measuring 65 mm in length, including the head, and 9 mm in diameter. The head is torx shaped. Although this bolt attaches the connecting rod in the same fashion as the item above, the connecting rod where this part is used has internal threading. Therefore, the fastener is torqued at the head.

The applicable subheading for the connecting rod bolt, part 996 103 176 70, will be 7318.15.2095, 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: other screws and bolts, whether or not with their nuts or washers: bolts and bolts and their nuts or washers entered or exported in the same shipment: having shanks or threads with a diameter of 6 mm or more: other: other: other. The rate of duty will be free.

The applicable subheading for the connecting rod bolt, part 997 103 115 01, will be 7318.15.8085, 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: 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: other. The rate of duty will be 8.5% ad valorem.

Consideration was given to classifying the connecting rod bolt, part 996 103 176 70, within subheading 7318.15.5060, HTS, as you had suggested, however, there is nothing within its design features that will anchor it in place.

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,

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