## Facts

- Honda of America Manufacturing, Inc. imported “oil bolts” between 2002 and 2004 for use in automobiles and motorcycles.
- The oil bolts had a smooth upper portion and a hollow, threaded body (some with extended stems) and were used to connect fluid lines to brake master cylinders or transmission cases while allowing fluid to flow without leaking.
- Customs classified the merchandise under HTSUS subheading 7318.15.80 as iron or steel bolts with threaded shanks of 6 mm or more, subject to duty as “parts of general use.”
- Honda protested, arguing the items were specialized vehicle components and should be classified as motor-vehicle “parts and accessories” under HTSUS heading 8708.
- Customs issued Headquarters rulings maintaining classification under heading 7318.
- The Court of International Trade granted summary judgment to the United States, upholding Customs’ classification; Honda appealed.

## Issues

1. Whether the imported oil bolts fall within HTSUS heading 7318 as iron or steel “bolts” and therefore constitute “parts of general use.”
2. Whether the oil bolts’ specialized design and exclusive use in vehicle brake or transmission systems permits classification under HTSUS heading 8708 as motor-vehicle “parts and accessories,” notwithstanding the section notes excluding “parts of general use.”

## Decision

- The Federal Circuit affirmed the Court of International Trade’s grant of summary judgment to the United States.
- The court held the oil bolts are classifiable under HTSUS heading 7318, subheading 7318.15.80, as bolts (parts of general use).
- The court held the oil bolts are excluded from classification under HTSUS heading 8708 by the HTSUS section notes governing “parts of general use.”

## Legal Principles

- HTSUS classification is governed by the General Rules of Interpretation, relevant section and chapter notes, and (as persuasive guidance) the Explanatory Notes.
- Section XV note 2 defines “parts of general use” and directs that qualifying base-metal fasteners are classified in specified headings, including heading 7318.
- Section XVII note 2(a) excludes “parts of general use” (as defined in Section XV) from classification as motor-vehicle “parts and accessories” under Chapter 87, including heading 8708.
- Specialized features and dedicated end use do not remove an article from a heading that covers “parts of general use” when controlling legal notes require classification in the general-use heading.

## Conclusion

Because the merchandise was commercially and functionally a bolt and the HTSUS notes treat such fasteners as “parts of general use” that are excluded from Chapter 87, the Federal Circuit upheld Customs’ classification under heading 7318 rather than heading 8708.


Honda of Am. Mfg., Inc. v. United States, 607 F.3d 771 (Fed. Cir. 2010)