Tariff Classification of “Oil Bolts”

(Leagle.com)

HONDA OF AMERICA MFG., INC., Plaintiff-Appellant,
v. UNITED STATES, Defendant-Appellee
No. 2009-1493
United States Court of Appeals, Federal Circuit
Decided: June 2, 2010

In 2002-2004, Honda imported “oil bolts” used in its cars and motorcycles. Pl.’s Compl. 2. These oil bolts feature a smooth upper portion with a hollow, threaded body, some of which have extended stems. The oil bolts connect fluid lines to brake master cylinders or transmission cases, allowing fluid to flow through without leaking. Honda’s Principal Br. 5-8. Customs classified the oil bolts under Schedule subheading 7318.15.80: “Screws, bolts, nuts, . . . and similar articles, of iron or steel . . . [t]hreaded articles . . . [h]aving shanks or threads with a diameter of 6 mm or more.” Customs Headquarters Ruling No. 966412 (Sept. 3, 2003), aff’d, Customs Head-quarters Ruling No. 966789 (June 21, 2004). Customs liquidated at the corresponding 8.5% duty.

Honda appealed to the CIT, arguing that the proper classification is one of three subheadings in Schedule Chapter 87, “Vehicles . . . and Parts and Accessories Thereof.” On Honda’s motion, the CIT designated this case a test case for four others. Both parties cross-moved for summary judgment. The CIT granted the government’s motion, holding that Customs correctly classified the oil bolts as “parts of general use,” even though the bolts have specialized features, because the Schedule “does not generally make an exception for specialized parts.” Honda, 625 F. Supp. 2d at 1327. Honda appeals, and we have jurisdiction under 28 U.S.C. § 1295(a)(5).

Read the complete decision and discussion here.