H345634

H345634 December 16, 2025 OT:RR:CTF:CPMMA H345634 DCC CATEGORY: Classification TARIFF NO.: 8302.10.3000 Center Director Automotive and Aerospace Center for Excellence and Expertise U.S. Customs & Border Protection 477 Michigan Ave. Detroit, MI 48226 Attn: Supervisory Import Specialist Mark Badger RE: Request for Further Review of Protest No. 1803-25-102577; Tariff Classification of Certain Hinges Dear Center Director: This is in response to the Application for Further Review (AFR) of Protest No. 1803-25- 102577, filed on February 18, 2025, by Jammy, Incorporated, (Jammy or Protestant), contesting U.S. Customs and Border Protection’s (CBP) classification of certain door hinges for recreational vehicles (RVs) under the Harmonized Tariff Schedule of the United States (HTSUS). The Protest concerns one entry of merchandise that was made on October 16, 2024, and liquidated on December 13, 2024. Counsel for Jammy submitted a Memorandum in Support of Protest. FACTS: In the Memorandum in Support of Protest, counsel for Jammy describes the subject merchandise as follows: The imported articles, identified as TALH Series hinges, are three and five leaf aluminum door hinges in raw and black finishes, designed for use on the entry doors of recreational vehicles. The five leaf version measures 7-3/4” long and weighs 0.32 pounds (lbs.) (5.12oz) each. The three leaf version measures 4-5/8” long and weighs 0.2 lbs. (3.2oz). A box of hinges contains 50 items. Each hinge is composed of three or five aluminum leaves, each leaf with stamped mounting holes. Each hinge is imported with a stainless-steel hinge pin about which the hinge rotates, with each leaf separated by nylon washers. In addition, the Protestant’s product website, https://jammyinc.com/product- category/leaf-door-hinges/ (last visited November 18, 2025), describes the subject merchandise as follows: Three and Five Leaf Aluminium [sic] Door Hinges in Raw (R) and Black (B) Finishes. Designed for use on RV and Trailer Doors. Stainless hinge pin with nylon washers. Black version is E-Coat finish for longest outdoor durability. Five Leaf Version is 7-3/4” Long Three Leaf Version is 4-5/8” Long Each 3-Hole Leaf is 4mm (0.157”) offset from 2-Hole Leaf to allow for fasteners. In addition, the following table, available on Jammy’s product website (last visited November 18, 2025), identifies the four models by part number: Part No. Description Finish TALH5B 5 Leaf Aluminum Door Hinge Black TALH5R 5 Leaf Aluminum Door Hinge Raw Aluminum TALH3B 3 Leaf Aluminum Door Hinge Black TALH3R 5 Leaf Aluminum Door Hinge Raw Aluminum In the Memorandum in Support of Protest, counsel for Jammy states that the TALH series hinges are used as entry door hinges for various vehicles, including motor vehicles, recreational vehicles, motorhomes, buses, campers, trailers, camper trailers, and towable travel trailers. At the time of entry, the Protestant classified the hinges in subheading 8302.10.3000, HTSUSA (Annotated), subject to the column one general rate of duty of 2% ad valorem. Subheading 8302.10.3000, HTSUSA, provides for “Base metal mountings, fittings and similar articles . . . : Hinges, and parts thereof: Of iron or steel, of aluminum or of zinc: Designed for motor vehicles.” In a Notice of Action dated November 26, 2024, CBP notified Jammy that, The correct HTSUS number for this merchandise is 8302.10.6090. This entry summary will be rate advanced and a bill will be issued upon liquidation. Line 002 will be edited to HTS 8302.10.6090 / 9903.88.03 with applied duty rate of 3.5% and Section 301 duties of 25%. Subheading 8302.10.6090, HTSUSA, provides for “Base metal mountings, fittings and similar articles . . . : Hinges, and parts thereof: Of iron or steel, of aluminum or of zinc: Other: Other.” 2 ISSUE: Whether the TALH hinges are properly classified in subheading 8302.10.30, HTSUS, as hinges designed for motor vehicles, or in subheading 8302.10.60, HTSUS, as “other” hinges. LAW AND ANALYSIS: Initially, we note that the matter is protestable under 19 U.S.C. § 1514(a)(2) as a decision on tariff classification. Jammy timely filed the protest within 180 days from the date of liquidation for entries made on or after December 18, 2004. See Miscellaneous Trade and Technical Corrections Act of 2004, Pub. L. 108-429, § 2103(2)(B)(ii), (iii) (codified as amended at 19 U.S.C. § 1514(c)(3) (2006)). Further review of the protest is properly granted pursuant to 19 C.F.R. § 174.24(b) because the decision against which the protest was filed is alleged to be inconsistent with rulings by CBP and involve questions of law or fact which have not been ruled upon by the Customs courts. Merchandise imported into the United States is classified under the HTSUS. The tariff classification of merchandise under the HTSUS is governed by the principles set forth in the General Rules of Interpretation (GRIs) and, in the absence of special language or context which otherwise requires, by the Additional U.S. Rules of Interpretation. The GRIs and the Additional U.S. Rules of Interpretation are part of the HTSUS and are to be considered statutory provision of law for all purposes. See Sections 1204(a) and 1204(c) of the Omnibus Trade and Competitiveness Act of 1988 (19 U.S.C. §§ 1204(a) and 1204(c)). GRI 1 provides that classification shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. When goods cannot be classified solely based on GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. GRI 6 provides that for legal purposes, the classification of goods in the subheadings of a heading shall be determined according to the terms of those subheadings and any related subheading notes and, mutatis mutandis, to the above rules, on the understanding that only subheadings at the same level are comparable. Under GRI 1, “classification shall be determined according to the terms of the headings and any relative section or chapter notes.” See Orlando Food Corp. v. United States, 140 F.3d 1437, 1440 (Fed. Cir. 1998). “Absent contrary legislative intent, HTSUS terms are to be construed according to their common and commercial meanings, which are presumed to be the same. A court may rely upon its own understanding of the terms used and may consult lexicographic and scientific authorities, dictionaries, and other reliable information sources.” Carl Zeiss, Inc. v. United States, 195 F.3d 1375, 1379 (Fed. Cir. 1999) (internal citation omitted); see also Rocknel Fastener, Inc. v. United States, 267 F.3d 1354, 1356-57 (Fed. Cir. 2001). The HTSUS subheadings under consideration are the following: 8302 Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the 3 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: 8302.10 Hinges, and parts thereof: Of iron or steel, of aluminum or of zinc: 8302.10.3000 Designed for motor vehicles. 8302.10.60 Other 8302.10.6090 Other. The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the official interpretation of the Harmonized System at the international level. Although neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). Explanatory Note (C) to Section XV provides as follows: (C) PARTS OF ARTICLES In general, identifiable parts of articles are classified as such parts in their appropriate headings in the Nomenclature. However, parts of general use (as defined in Note 2 to this Section) presented separately are not considered as parts of articl

Initially, we note that the matter is protestable under 19 U.S.C. § 1514(a)(2) as a decision on tariff classification. Jammy timely filed the protest within 180 days from the date of liquidation for entries made on or after December 18, 2004. See Miscellaneous Trade and Technical Corrections Act of 2004, Pub. L. 108-429, § 2103(2)(B)(ii), (iii) (codified as amended at 19 U.S.C. § 1514(c)(3) (2006)). Further review of the protest is properly granted pursuant to 19 C.F.R. § 174.24(b) because the decision against which the protest was filed is alleged to be inconsistent with rulings by CBP and involve questions of law or fact which have not been ruled upon by the Customs courts. Merchandise imported into the United States is classified under the HTSUS. The tariff classification of merchandise under the HTSUS is governed by the principles set forth in the General Rules of Interpretation (GRIs) and, in the absence of special language or context which otherwise requires, by the Additional U.S. Rules of Interpretation. The GRIs and the Additional U.S. Rules of Interpretation are part of the HTSUS and are to be considered statutory provision of law for all purposes. See Sections 1204(a) and 1204(c) of the Omnibus Trade and Competitiveness Act of 1988 (19 U.S.C. §§ 1204(a) and 1204(c)). GRI 1 provides that classification shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. When goods cannot be classified solely based on GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order. GRI 6 provides that for legal purposes, the classification of goods in the subheadings of a heading shall be determined according to the terms of those subheadings and any related subheading notes and, mutatis mutandis, to the above rules, on the understanding that only subheadings at the same level are comparable. Under GRI 1, “classification shall be determin