Staff Contact: William F. Mascaro Telephone (703) Item Description Class

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1 Re: Automobile Parts Various Items Staff Contact: William F. Mascaro Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class AUTOMOBILE PARTS GROUP: subject to item Body Parts; Parts; or Trim; viz.: Body Parts, NOI, see Notes, items 18262, 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, 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, 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 Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 or greater 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 National Motor Freight Traffic Association, Inc. Subject 3, Page 1 of 8

2 Present Classification Provisions Concluded Item Description Class AUTOMOBILE PARTS GROUP: subject to item Parts, NOI, other than tanks; or Driving Gear or Steering Gear Parts, NOI: Aluminum, brass, bronze, copper or magnesium alloy, in packages Babbitt metal, white metal alloy, zinc or zinc alloy, in packages Iron or steel, see Note, item 19162: Sub 1 Weighing each less than 50 pounds, loose Sub 2 Weighing each less than 50 pounds, in packages; or weighing each 50 pounds or over, loose, in packages or on skids 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 Parts, obsolete (not suitable for reselling), having value only for reclamation of raw materials, prepaid, see Notes, items 19166, and 19182, in packages 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 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 Parts, used, see Notes, items 19181, and 19183, in packages 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 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 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 National Motor Freight Traffic Association, Inc.

3 Proposed Classification Provisions Item Description Class AUTOMOBILE PARTS GROUP: subject to item Body Parts; Parts; or Trim; viz.: Body Parts, NOI, see Notes, items 18262, 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, 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, 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 Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE No Change NOTE No Change NOTE No Change NOTE No Change National Motor Freight Traffic Association, Inc. Subject 3, Page 3 of 8

4 Proposed Classification Provisions Concluded Item Description Class AUTOMOBILE PARTS GROUP: subject to item Parts, NOI, other than tanks; or Driving Gear or Steering Gear Parts, NOI... Cancel; see item Aluminum, brass, bronze, copper or magnesium alloy, etc... Cancel; see item Babbitt metal, white metal alloy, zinc or zinc alloy, etc... Cancel; see item Iron or steel, etc... Cancel; see item NOTE Cancel; no further application Parts, obsolete (not suitable for reselling), having value only for reclamation of raw materials, etc... Cancel; see item or provisions otherwise applicable NOTE Cancel; no further application NOTE Cancel; no further application Parts, used, etc... Cancel; see item 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, and 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 National Motor Freight Traffic Association, Inc.

5 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, and were adopted from the rails in 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 NMFC TM has contained a provision for used automobile parts dating back to The current provisions of item 19180, applying on Parts, used, were established as a result of action taken on Docket , 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 and its subordinate provisions, items 19120, 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 Study 1. The densities range from 0.10 to pcf, with a simple average density of pcf. A frequency distribution of the overall density range is shown on the following page. 1 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 NMFC TM item, and only verifiable data points, which include the weight and the dimensions and/or cube of the shipping unit involved, are used National Motor Freight Traffic Association, Inc. Subject 3, Page 5 of 8

Frequency Distribution % of Figures in Interval 25% 20% 15% 10% 5% 0% 0% 0% 9% 9% 8% 8% 7% 19% 24% 7% 8% Density Intervals (pcf) The frequency distribution shows that the density figures are

6 Frequency Distribution % of Figures in Interval 25% 20% 15% 10% 5% 0% 0% 0% 9% 9% 8% 8% 7% 19% 24% 7% 8% 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 National Motor Freight Traffic Association, Inc.

7 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 pcf, with a simple average density of 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, and 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 and items 19120, and National Motor Freight Traffic Association, Inc. Subject 3, Page 7 of 8

8 In keeping with CCSB policy, this proposal would cancel the provisions of items 19100, 19120, and with reference to the density-based provisions of item Concurrently, item 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 would also be extended to provide the CCSB s standard 11-subprovision progression 3. This proposal would also cancel items and 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 applies on automobile parts that are obsolete, i.e. not suitable for reselling, and having value only for reclamation of raw materials, while item 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 and with reference to item or the provisions otherwise applicable, as proposed, is in keeping with CCSB policy. With the cancellation of items 19160, and 19180, the cancellation of Notes, items 19162, 19166, 19167, 19181, and 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. 2 The present density scale in item was established as a result of action taken on Docket , Subject 5 (January 2012). This was a proposal which sought to, in part, replace the truncated density scale in item 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 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, The CCSB s standard 11-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 3, Page 8 of National Motor Freight Traffic Association, Inc.

CCSB Contact: Erin N. Topper Telephone (703) Item Description Class

Re: Welding Bars, Rods or Wire (Welding Electrodes), iron or steel CCSB Contact: Erin N. Topper Telephone (703) 838-8856 topper@nmfta.org Proponent: Commodity Classification Standards Board Present Classification