&&The product at issue is a steel ground screw with a built-in steel flange plate. This product is used to secure a solar racking system to the ground.

&&Note 2(a) to Section XV states the following:&&&&“Throughout the Nomenclature, the expression “parts of general use” means:&&&&• (a) Articles of heading 73.07, 73.12, 73.15, 73.17 or 73.18 and similar articles of other base metals;&&&&In Chapters 73 to 76 and 78 to 82 (but not in heading 73.15) references to parts of goods do not include references to parts of general use as defined above”.&&&&The General Explanatory Note (C) Parts of Articles to Section XV states the following:&&&&“In general, identifiable parts of articles are classified as such parts in their appropriate headings in the Nomenclature.&&&&However, parts of general use (as defined in Note 2 to this Section) presented separately are not considered as parts of articles, but are classified in the headings of this Section appropriate to them”.&&&&Heading 73.18 provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter-pins, washers (including spring washers) and similar articles, of iron or steel.&&&&Explanatory Note (A) to heading 73.18 states that the heading includes all types of fastening bolts and metal screws regardless of shape and use.&&