Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs), and the Additional U.S. Rules of Interpretation explain that “(c) a provision for parts of an article covers products solely or principally used as a part of such articles but a provision for “parts” or “parts and accessories” shall not prevail over a specific provision for such part or accessory . . .”. Relevant chapter notes, section notes, and explanatory notes (although not legally binding) provide further tests for when merchandise may be considered a “part.”
A recently published ruling (HQ H185723 – found in the Customs Bulletin VOL. 50, NO. 16, Apr. 20, 2016) further elucidates which items may be considered “parts.” In the ruling, CBP classified certain nozzles for dispersing or spraying high-pressure liquids under 8424.90.90 (parts of mechanical appliances for projecting, dispersing or spraying liquids or powders) rather than HTSUS 7326.90.85 (other articles of iron or steel). In reaching this decision, CBP reviewed the relevant section notes and explanatory notes, and found that the nozzles are intended solely or principally with spraying machines and do not fall under a specific provision that precludes them from being classified as parts.