CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
Re: Automobile Parts — Various Items
Staff Contact: William F. Mascaro
Telephone — (703) 838-1834
mascaro@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
18260
Sub 1
Sub 2
Sub 3
Sub 4
Sub 5
Sub 6
Sub 7
Sub 8
Sub 9
18262
18265
18266
18267
Description
Class
AUTOMOBILE PARTS GROUP: subject to item 17800
Body Parts; Parts; or Trim; viz.:
Body Parts, NOI, see Notes, items 18262, 18265 and 18266;
Brush Guards, Grille Guards, Bull Bars or Push Bars, separate or
combined with bumpers;
Bumpers or Bumper Fittings, NOI, plastic, front or rear end protection;
Frames or Holders, automobile license plate or personal identification
plate, plastic, with or without fasteners;
Louvers, air conditioning, heating or ventilating;
Parts, NOI, plastic or rubber, separate or combined with other materials,
see Notes, items 18262, 18265 and 18266;
Pickup Truck Bed Liners, molded plastic;
Repair Panels, NOI, see Note, item 18267;
Running Boards, NOI, with or without splash guards, step plates or lights;
Trim, body, fender, front end, rear end or roof, see Notes, items 18262,
18265 and 18266;
Wheel Covers, Trim Rings or Rims, or Hubcaps, other than grease caps;
In packages, subject to Items 170 and 171 and having a density in
pounds per cubic foot of:
Less than 1 .......................................................................................... 400
1 but less than 2 .................................................................................. 300
2 but less than 4 .................................................................................. 250
4 but less than 6 .................................................................................. 150
6 but less than 8 .................................................................................. 125
8 but less than 10 ................................................................................ 100
10 but less than 12 ................................................................................ 92.5
12 but less than 15 ................................................................................ 85
15 or greater ......................................................................................... 70
NOTE—Also applies when parts or trim have weatherstripping, sound or shock
absorbing or deadening material, or gaskets or similar material attached.
NOTE—Applies on parts or trim, whether for interior or exterior installation and
whether constituting a structural part of the body or constituting a part of
the body interior furnishing or equipment.
NOTE—Does not apply on: cellular, expanded or foam plastic or rubber
insulation; pads or padding; carpets or carpeting; or tanks.
NOTE—Not Involved.
©2013 National Motor Freight Traffic Association, Inc.
Subject 3, Page 1 of 8
CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
Present Classification Provisions — Concluded
Item
Description
Class
AUTOMOBILE PARTS GROUP: subject to item 17800
19100
Parts, NOI, other than tanks; or Driving Gear or Steering Gear Parts, NOI:
19120
Aluminum, brass, bronze, copper or magnesium alloy, in packages ......... 92.5
19140
Babbitt metal, white metal alloy, zinc or zinc alloy, in packages ............... 92.5
19160
Iron or steel, see Note, item 19162:
Sub 1
Weighing each less than 50 pounds, loose ........................................... 100
Sub 2
Weighing each less than 50 pounds, in packages; or weighing
each 50 pounds or over, loose, in packages or on skids ............ 85
19162
NOTE—Also applies on parts made of a combination of iron or steel and other
materials provided the weight of the other materials does not exceed 10
percent of the total weight.
19165
Parts, obsolete (not suitable for reselling), having value only for reclamation
of raw materials, prepaid, see Notes, items 19166, 19167 and 19182,
in packages ............................................................................................... 70
19166
NOTE—Other classification items showing more specific descriptions of
individual parts will not apply to such obsolete (not suitable for reselling)
parts unless the provisions in such items are lower than those provided
herein.
19167
NOTE—Applies only when the parts are obsolete (not suitable for reselling) and
have value only for the salvage of raw materials, and only when
described at time of shipment on shipping orders and bills of lading as
‘Parts, automobile, obsolete (not suitable for reselling), having value only
for reclamation of raw materials.’
19180
Parts, used, see Notes, items 19181, 19182 and 19183, in packages ................ 70
19181
NOTE—Other classification items showing more specific descriptions of
individual parts, but which make no distinction between new and used
parts, will not apply to such used parts unless the provisions in such items
are lower than those provided herein.
19182
NOTE—Except bodies; body sections, NOI; body sections combined with
hoods, fenders, rear decks, radiators or other parts; hoods, doors, fenders,
rear decks or radiators, separate or combined, or combined with other
automobile parts; quarter panel assemblies, with or without wheelhouses;
cowl top assemblies; lower back assemblies; wheelhouses; rear deck tops;
rear windows; dashboards (dashes); roofs; floor pans; shrouds; hinge pillar
assemblies; center pillars; rocker panels; instrument panels; rear
compartment pans; or seats.
19183
NOTE—Applies only when the parts are used and have value not exceeding
the value for reconditioning or salvaging purposes, and only when
described at time of shipment on shipping orders and bills of lading as
‘used automobile parts.’ Used parts that have been reconditioned or
rebuilt in any way will be classified under the specific classification item
number as new.
Subject 3, Page 2 of 8
©2013 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
Proposed Classification Provisions
Item
Description
Class
AUTOMOBILE PARTS GROUP: subject to item 17800
18260
Body Parts; Parts; or Trim; viz.:
Body Parts, NOI, see Notes, items 18262, 18265 and 18266;
Brush Guards, Grille Guards, Bull Bars or Push Bars, separate or
combined with bumpers;
Bumpers or Bumper Fittings, NOI, plastic, front or rear end protection;
Driving Gear or Steering Gear Parts, NOI;
Frames or Holders, automobile license plate or personal identification
plate, plastic, with or without fasteners;
Louvers, air conditioning, heating or ventilating;
Parts, NOI, see Notes, items 18262, 18265 and 18266;
Pickup Truck Bed Liners, molded plastic;
Repair Panels, NOI, see Note, item 18267;
Running Boards, NOI, with or without splash guards, step plates or lights;
Trim, body, fender, front end, rear end or roof, see Notes, items 18262,
18265 and 18266;
Wheel Covers, Trim Rings or Rims, or Hubcaps, other than grease caps;
In packages, subject to Items 170 and 171 and having a density in
pounds per cubic foot of:
Sub 1
Less than 1 .......................................................................................... 400
Sub 2
1 but less than 2 .................................................................................. 300
Sub 3
2 but less than 4 .................................................................................. 250
Sub 4
4 but less than 6 .................................................................................. 150
Sub 5
6 but less than 8 .................................................................................. 125
Sub 6
8 but less than 10 ................................................................................ 100
Sub 7
10 but less than 12 ................................................................................ 92.5
Sub 8
12 but less than 15 ................................................................................ 85
Sub 9
15 but less than 22.5 ............................................................................. 70
Sub 10
22.5 but less than 30 ............................................................................. 65
Sub 11
30 or greater ......................................................................................... 60
18262
NOTE—No Change.
18265
NOTE—No Change.
18266
NOTE—No Change.
18267
NOTE—No Change.
©2013 National Motor Freight Traffic Association, Inc.
Subject 3, Page 3 of 8
CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
Proposed Classification Provisions — Concluded
Item
19100
19120
19140
19160
19162
19165
19166
19167
19180
19181
19182
19183
Description
Class
AUTOMOBILE PARTS GROUP: subject to item 17800
Parts, NOI, other than tanks; or Driving Gear or Steering Gear
Parts, NOI ................................................................................... Cancel; see
item 18260
Aluminum, brass, bronze, copper or magnesium alloy, etc ....... Cancel; see
item 18260
Babbitt metal, white metal alloy, zinc or zinc alloy, etc .............. Cancel; see
item 18260
Iron or steel, etc .............................................................................. Cancel; see
item 18260
NOTE—Cancel; no further application.
Parts, obsolete (not suitable for reselling), having value only for
reclamation of raw materials, etc ........................................... Cancel; see
item 18260 or
provisions otherwise
applicable
NOTE—Cancel; no further application.
NOTE—Cancel; no further application.
Parts, used, etc ..................................................................................... Cancel; see
item 18260 or
provisions otherwise
applicable
NOTE—Cancel; no further application.
NOTE—Cancel; no further application.
NOTE—Cancel; no further application.
Analysis
Research Project 1152
This proposal is based on information developed through Research Project 1152, which
was initiated in February 2012 to investigate the transportation characteristics of automobile
parts, as classified in items 19100, 19120, 19140, 19160, 19165 and 19180. As part of the
research, 138 potential manufacturers or shippers and 12 trade associations were contacted
in June 2012, and for those that did not respond, again in August 2012, inviting them to
participate. From this sampling, six of the shipper surveys were returned as undeliverable,
seven companies responded that they did not manufacture or ship the involved articles, and
two companies provided at least some information. The information was not usable, however.
With respect to the associations, one association responded that it is their policy not to
participate in surveys. No response was received from the remaining 11 associations.
Subject 3, Page 4 of 8
©2013 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
History of Provisions
The provisions of item 19100, “Parts, NOI, other than tanks; or Driving Gear or Steering
Gear Parts, NOI,” and its subordinate provisions, items 19120, 19140 and 19160 were adopted
from the rails in 1936. There have been some amendments to these provisions over the years,
including class adjustments, packaging changes and the addition of other materials of
construction.
Item 19165, applying on “Parts, obsolete (not suitable for reselling), having value only for
reclamation of raw materials,” was established as a result of action taken on Docket 765,
Subject 10 (July 1976). That was a proposal to specifically provide for shipments of obsolete
(unsalable) automobile parts moving from dealers and parts distribution centers to scrap
yards. The proposal was approved as modified. The item first appeared in Supplement 1 to
NMF 100-D, effective April 2, 1977 and has remained substantially unchanged to the present.
A review of historical records reveals that the NMFCTM has contained a provision for
used automobile parts dating back to 1940. The current provisions of item 19180, applying on
“Parts, used,” were established as a result of action taken on Docket 2000-1, Subject 15
(February 2000). That was a proposal to provide, in part, a separate provision for used
automobile parts at the currently applicable class 70. Formerly, used automobile parts were
grouped in a provision with used automobile engines. The proposal was approved as
docketed. The changes first appeared in Supplement 4 to NMF 100-Z, effective April 29, 2000,
and the item has remained unchanged to the present.
About Automobile Parts
Item 19100 and its subordinate provisions, items 19120, 19140 and 19160, apply on a
wide variety of metallic automobile parts, including driving gear or steering gear parts, which
are not more specifically named in the NMFC™. This proposal also involves obsolete parts, as
named in item 19165, having no value other than for reclamation of raw materials, and used
parts, as named in item 19180, which have value not exceeding the value for reconditioning
or salvaging purposes.
Transportation Characteristics
Density—The information of record encompasses 36,980 density observations from a variety of
sources, including carrier-supplied data, CCSB dock surveys, and the CCSB’s Density Study1.
The densities range from 0.10 to 98.25 pcf, with a simple average density of 15.05 pcf. A
frequency distribution of the overall density range is shown on the following page.
The Density Study is part of an ongoing effort by the CCSB to collect information on actual shipments; it
is not tied to any particular research project, nor does it target any particular product category. Carriers
that choose to participate in the study periodically submit shipment data captured through their
respective freight auditing programs. The data is identified by NMFCTM item, and only verifiable data
points, which include the weight and the dimensions and/or cube of the shipping unit involved, are
used.
1
©2013 National Motor Freight Traffic Association, Inc.
Subject 3, Page 5 of 8
CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
% of Figures in Interval
Frequency Distribution
24%
25%
19%
20%
15%
9%
10%
5%
0%
9%
8%
8%
7%
7%
8%
0%
0%
Density Intervals (pcf)
The frequency distribution shows that the density figures are distributed throughout the
range. It is also noted that 20% of the figures exceed 20 pcf.
Handling—As a result of the diverse nature of products moving under the involved items, they
have been found to be tendered in a variety of different manners, including fully enclosed
within fiberboard boxes or reusable shipping containers, which may or may not be secured on
lift truck skids or pallets, and on occasion, loose. However, of the shipments where packaging
is known, the vast majority are tendered fully enclosed within fiberboard boxes or reusable
shipping containers.
When tendered fully enclosed within boxes or reusable shipping containers secured on
lift truck skids or pallets, handling should be similar to that of other like-packaged freight, and
no unusual considerations are noted. Loose automobile parts are generally more difficult to
handle than packaged parts due to the absence of a protective covering and the resulting
need for additional care and attention to prevent damage. Additional time may also be
required for normal cross-dock operations due to the potential inability to use mechanical
handling equipment.
Stowability—Automobile parts tendered loose may pose some stowability considerations.
Specifically, articles tendered in this manner will generally lack a flat load-bearing surface for
stowing other freight on top. They may also have protrusions and exposed surfaces or edges
that can limit the type of freight that may be safely loaded adjacent to them. In the LTL
environment, this means that carriers may not be able to load other freight on top of or
adjacent to the unit, or that they may have to employ the use of load decks and/or dunnage,
resulting in an associated increase in time necessary to structure the load. However, as
mentioned under the handling discussion, the majority of the observations of record are in
boxes or reusable shipping containers, and no specific stowability issues have been reported
by carriers.
Subject 3, Page 6 of 8
©2013 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
Liability—Automobile parts are not perishable, prone to spontaneous combustion or explosion
or unusually susceptible to theft. Research has identified a wide variety of methods of tender,
i.e. fully enclosed within a box or reusable shipping container, which may or may not be
secured on lift truck skids or pallets, or loose. As is the case with most general commodities,
being fully enclosed within a box or reusable shipping container will offer greater protection
against damage. There is no information available regarding the value of the involved
automobile parts, nor is there any indication of a claims problem.
Relationship to CCSB Policies and Guidelines
CCSB policy calls for classification provisions to reflect a commodity’s known
transportation characteristics. Information of record indicates that the involved automobile
parts range in density from 0.10 to 98.25 pcf, with a simple average density of 15.05 pcf. CCSB
policy states that commodities or commodity groups exhibiting a wide density range not
accurately reflected by a single overall average density may be assigned density-based
classes; especially where there are no unusual or significant handling, stowability or liability
characteristics and where there is no other feasible means of effectively narrowing the range.
And where densities are distributed throughout the range, commodities or commodity groups
may be assigned classes predicated on a full density scale. Further, when a substantial
percentage of the densities involved exceeds 20 pcf, full-scale density classifications should
generally provide the standard eleven-sub progression that ranges from class 400 assigned to
articles with densities of less than 1 pcf to class 60 assigned to articles with densities of 30 pcf or
greater. Twenty percent of the density figures of record exceed 20 pcf.
It is noted that while some negative handling, stowability and liability considerations
have been identified, these can be somewhat mitigated by the elimination of the allowance
for loose shipments. Also, it has been found that the majority of the shipments on which
information regarding packaging is available were tendered in boxes or reusable shipping
containers. These packaging methods, as noted, generally provide for optimal handling and
stowability. Furthermore, there is no indication of a claims problem.
CCSB policy also calls for classification provisions to be as clear as possible to help
preclude interpretation disputes. Items 19120, 19140 and 19160 reference automobile parts
made of a variety of different metals or metal alloys. Distinguishing between these different
types of metals may be difficult for the carrier. Also, item 19160, which applies on iron or steel
automobile parts, allows for parts combined with other materials provided the weight of the
other materials does not exceed 10 percent of the total weight. Again, carriers may have
considerable difficulty determining if a particular part complies with the restriction. Similarly,
distinguishing between item 19165, which applies on obsolete automobile parts having value
only for reclamation of raw materials, and item 19180, which applies on used automobile parts
having value for reconditioning or salvaging purposes, may be difficult if not impossible. And,
as an obsolete part does not have to be used, it may be equally difficult to distinguish
between item 19165 and items 19120, 19140 and 19160.
©2013 National Motor Freight Traffic Association, Inc.
Subject 3, Page 7 of 8
CCSB DOCKET 2013-2
SECTION I
SUBJECT 3
In keeping with CCSB policy, this proposal would cancel the provisions of items 19100,
19120, 19140 and 19160 with reference to the density-based provisions of item 182602.
Concurrently, item 18260 would be amended to include a reference to “Driving Gear or
Steering Gear Parts, NOI,” and the restriction found in the reference to “Parts, NOI” limiting its
application to “plastic or rubber, separate or combined with other materials” would be
removed. The density scale in item 18260 would also be extended to provide the CCSB’s
standard 11-subprovision progression3.
This proposal would also cancel items 19165 and 19180 in keeping with CCSB policy
calling for providing uniformity in provisions addressing the same or similar circumstances
published in conjunction with different items. As previously discussed, item 19165 applies on
automobile parts that are obsolete, i.e. not suitable for reselling, and having value only for
reclamation of raw materials, while item 19180 applies on used automobile parts having value
for reconditioning or salvage purposes. Parts not meeting the conditions of these items are
provided for in other items, including item 18260, at a class or classes reflective of their
respective transportation characteristics. Canceling the provisions of items 19165 and 19180
with reference to item 18260 or the provisions otherwise applicable, as proposed, is in keeping
with CCSB policy.
With the cancellation of items 19160, 19165 and 19180, the cancellation of Notes, items
19162, 19166, 19167, 19181, 19182 and 19183 with no further application, as proposed, is in
keeping with CCSB clarification policy.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy.
The present density scale in item 18260 was established as a result of action taken on Docket 2012-1,
Subject 5 (January 2012). This was a proposal which sought to, in part, replace the truncated density
scale in item 18260 then in effect with the CCSB’s standard nine-subprovision density scale. Information
from the record shows a range in density from 0.45 to 75.00 pcf, with a simple average density of 4.89
pcf, and that less than 3% of the density figures exceeded 20 pcf. The proposal was approved as
docketed, and the changes first appeared in Supplement 1 to NMF 100-AL, effective April 14, 2012.
3 The CCSB’s standard 11-subprovision density scale includes reference to Item (Rule) 170, the
inadvertence clause, and Item (Rule) 171, the “bumping” privilege.
2
Subject 3, Page 8 of 8
©2013 National Motor Freight Traffic Association, Inc.