Court: Court of Appeals for the Federal Circuit; October 4, 2001; Federal Appellate Court
Rocknel Fastener, Inc. appealed the decision of the Court of International Trade, which upheld the United States Customs Service's classification of imported metal fasteners under subheading 7318.15.80 of the Harmonized Tariff Schedule of the United States (HTSUS). The fasteners, imported from Japan in 1997, feature rod-shaped bodies with hexagonal heads and are designed for installation in assembled parts, with turning heads for tightening or release. Rocknel contended that the fasteners should fall under subheading 7318.15.20, which pertains to "bolts," while Customs classified them as "other" threaded items due to their diameter being six millimeters or more.
The Court determined that the terms "bolt" and "screw" should have mutually exclusive definitions, relying on the ANSI and ASME Specification B18.2.1 for accurate definitions. Since Rocknel acknowledged that under this specification, the fasteners were classified as screws, the court granted summary judgment to Customs, affirming the classification.
A tariff term's meaning, as a question of statutory construction, is determined through its common meaning when not defined in the Harmonized Tariff Schedule of the United States (HTSUS) or its legislative history. Courts may reference dictionaries and other reliable sources to establish this common meaning. The government agrees with the Court of International Trade that the ANSI Specification reflects the common meanings of "bolt" and "screw," while Rocknel challenges this assertion and argues that Customs has not demonstrated a need for a non-common meaning. The burden lies on the party contesting the common meaning to show that an alternative, uniform, and general commercial meaning exists.
Regarding Customs' classification decision, the Court of International Trade ruled, based on previous case law, that it should not receive deference. However, this conclusion was affected by the Supreme Court's ruling in United States v. Mead Corp., which clarified that Customs classification rulings are not entitled to Chevron deference unless a regulation is promulgated. Instead, such rulings merit deference under Skidmore principles, which evaluate the thoroughness, reasoning validity, and consistency of the ruling. The degree of deference is influenced by the ruling's thoroughness, logic, expertise, and alignment with prior interpretations.
Customs has not established a specific regulation defining "bolt" and "screw" within the tariff schedule, but it has consistently applied the ANSI Specification through various rulings and a publication over the past 16 years. These documents provide a detailed framework for distinguishing between bolts and screws, which is supported by long-standing Customs interpretations of the Harmonized Tariff Schedule of the United States (HTSUS). The Supreme Court ruling in Mead emphasizes that Customs' interpretations deserve judicial deference due to the complexity of the regulatory framework.
Rocknel contends that the Court of International Trade incorrectly assigned mutually exclusive definitions to "bolt" and "screw." Rocknel argues that since subheading 7318.15.20 classifies "bolts" specifically, any fastener meeting the bolt definition should be classified as such, regardless of its potential classification as a screw. However, the court upheld that the tariff structure mandates exclusive definitions for "bolt" and "screw." Consequently, classification must determine whether a fastener is a bolt or a screw, not allowing for dual classification.
The ANSI Specification, relied upon by Customs, outlines that a bolt is an externally threaded fastener intended for use with a nut, while a screw is designed to be inserted into a threaded or preformed hole and tightened by its head. The specification includes criteria defining bolts and screws, which the parties agree do not apply to the imported products in question.
Nine supplemental criteria are established to classify fasteners that do not meet the primary identification standards. If a fastener meets the majority of these criteria, it is classified as a screw. The criteria include: 1) a controlled fillet at the head-body junction; 2) a smooth and flat under head bearing surface; 3) controlled angularity of the under head surface; 4) accuracy in size and roundness of the body; 5) a straight shank; 6) concentric threads with the body axis; 7) adequate thread length for full strength; 8) a chamfered or specially prepared point; and 9) closely toleranced length. The parties concur that the imported fasteners fulfill a majority of these criteria.
Customs asserts that the definitions of bolts and screws in the ANSI Specification should guide tariff classifications, aligning with common terminology. Definitions from several technical and general dictionaries clarify that a bolt is an externally threaded fastener for insertion through assembled parts, typically secured with a nut, while a screw is designed for engagement with an internal thread or to form its own thread, tightened by turning the head. However, these definitions have exceptions, as screws can be used with nuts and bolts can fit into threaded holes. Various sources reaffirm these definitions, emphasizing the characteristics of bolts and screws as fasteners, with distinctions in their intended use and mechanisms for tightening.
Webster's New International Dictionary and ANSI Specification definitions for fasteners align closely, particularly regarding whether a fastener can be torqued by its head or a nut. The ANSI specification includes additional criteria that provide more detail than standard dictionary definitions. Rocknel proposed an open-ended definition of "bolt," stating it encompasses partially threaded fasteners that fasten objects and can be torqued. Rocknel contrasts bolts with screws, highlighting that screws are fully threaded, pointed, and typically turned with a screwdriver. However, Rocknel's definition is flawed; the distinction between fully and partially threaded fasteners is not found in dictionary definitions and relies on non-controlling Explanatory Notes from the HTSUS. Additionally, the factors Rocknel cites—fastening capability and torque application—do not effectively distinguish bolts from screws, as both serve similar functions. Given the lack of precision in dictionary definitions, Customs' adoption of ANSI definitions to differentiate between bolts and screws is reasonable and consistent with past practices in tariff term definitions.
The case does not involve a conflict between dictionary meanings and commercial standards but rather relies on an authoritative industry source that aligns with dictionary definitions, providing necessary precision. The court referenced previous cases indicating the use of such sources to support definitions. Applying the principles of deference from the Supreme Court's Mead decision, the court found Customs' interpretation of the statute persuasive and deserving of deference. Customs' definition aligns with dictionary meanings, is reflected in classification rulings and a specific publication, and stems from a national standard-making organization aimed at differentiating fasteners while preserving common understanding. The protesting party failed to present alternative definitions that would better aid classification decisions. Consequently, the judgment of the Court of International Trade, which upheld Customs' classification ruling, was affirmed.
