On June 2, 2010, the CAFC issued its decision in Honda of America MFG., Inc. v. United States, affirming a CIT ruling that CBP properly classified oil bolts manufactured by Honda under a category that simply includes screws, bolts and nuts. Specifically, CBP classified the oil bolts as “[s]crews, bolts or nuts” within HTSUS subheading 7318.15.80 at a duty rate of 8.5 percent ad valorem. Honda claimed that the imports should have instead been classified as one of three subheadings in Chapter 87 of the HTSUS as “Vehicles . . . and Parts Thereof.”
In making its determination, the CAFC rejected Honda’s argument that the Explanatory Notes (ENs) to Section 17 of the HTSUS warranted classification as vehicle parts and accessories. The CAFC noted that the oil bolts met only one of the three conditions set forth in the ENs—that the item be suitable principally for use with vehicles. The CAFC explained that the oil bolts failed to meet the condition that an item cannot be a part for general use. The CAFC further explained, citing special springs for motors as an example, that the oil bolts’ specialization for vehicles did not preclude its classification as a part for general use.