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Executive Summary for aviation-suppliers.org
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Page Title
ASA Web Log | The Aviation Suppliers Association
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The Aviation Suppliers Association
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Present
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ASA Web Log | The Aviation Suppliers Association
January 6, 2026by Jason DicksteinI have been seeing a number of companies having trouble with classifications. This is the first of what will likely be an occasional series discussing classification. This blog post will address fasteners.Please note that the following analysis is based on the regulations and standards as they are written today. Export and import law, is subject to change. This is particularly true of tariffs over the past year. So you should always verify your classification under the current regulations and standards.Classification is necessary for both exports and imports. Exports of civil aircraft parts are typically classified under Export Commodity Classification Numbers or ECCNs. An exception arises when the goods are controlled under the International Traffic in Arms Regulations (ITARs). Export ClassificationECCNs are typically five characters long. Many civil aircraft parts are characterized under ECCN 9A991. This ECCN applies to civil aircraft parts that are (1) not specified elsewhere and (2) specially designed for civil aircraft. The first condition is important because some parts (like engines, avionics, etc.) are specified elsewhere and may have different export limits and licensing provisions based on their proper classification. The second condition is equally important because the term “specially designed” is a legal term of art that has a specific definition under the Commerce Department regulations. The definition specifically excludes fasteners, so fasteners typically will not be classified under ECCN 9A991. Instead, they will typically be classified under EAR99.Import ClassificationImported goods are typically classified under harmonized tariff codes from the Harmonized Tariff Schedule of the United States (HTSUS). These codes can be ten digits long (when you include the statistical reporting number). There are also a lot more tariff numbers than there are ECCNs, which makes navigating the tariff schedule a little more daunting. Classifying fasteners for import can reflect a more complex analysis than what we just had to perform for fastener export classification. Normally, fasteners will be classified based on their material. An article made of iron or steel is typically classified within HTSUS Chapter 73 of the tariff schedule. This chapter is 45 pages long. Within the chapter are four-digit headings and the heading 7318 addresses fasteners (made from iron or steel). If the fastener is a bolt, then bolts made from iron or steel will be classified under 7318.15.20xx. This classification would also encompass bolts that are imported with their nuts or washers (the nuts and washers do not have to be declared separately). The final two characters (the “xx” in the example above) are the statistical reporting number and this number will depend on the size and nature of the bolt. If the bolt had a shank or threads less than 6mm, then the statistical reporting number would be “10” (so the full tariff code would be 7318.15.2010. If the shank or thread is 6mm or more then the nature of the bolt will drive the statistical reporting number: for example, a structural bolt is classified under 7318.15.2030. But if the same bolt was made from a different material then the importing tariff number could be different. An aluminum bolt would be found on the schedule for aluminum articles (HTSUS Chapter 76). It would be identified as 7616.10.xxxx. A threaded bolt with a shank or threads less than 6mm would be identified as 7616.10.7030. A threaded bolt with a shank or thread diameter of 6mm or more would be classified as 7616.10.9030.Proper tariff classification is important because different tariffs have different duty amounts. For example, the 7616.10.7030 bolt would be subject to a 5.5% duty rate when imported into the United States. The larger diameter 7616.10.9030 bolt would be subject to a 6% duty rate when imported into the United States. A common mistake is to classify these sorts of fasteners as aircraft parts under heading 8807, which is a general classification for aircraft parts that do not have a more specific code that describes them. Heading 8807 doesn’t apply to our fasteners because there are more specific classifications for bolts. This misclassification violates the import tariff rule that requires assignment of the most specific tariff description. It also leads to underpaid duties, which can lead to penalties when the underpayment is detected.;Network & Infrastructure
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The following issues occurred during analysis:
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Analyzed aviation-suppliers.org with 4 technologies detected across 5 categories
Analysis completed in 128 ms • 2026-03-23 09:44:17 UTC