CIT Flips Its Customs Ruling on 'Parts of Parts' for Aircraft Brake Discs

In January, Barnett said heading 8803 was the proper home for the goods, since the parts don't have any other purpose and don't require further processing before serving as brake disc components (see 2501300051). Specifically at issue are imported radial, web and chordal segments, which are made into needled preforms, which are then made into carbonized preforms. These preforms are then manufactured into carbon-carbon preforms, and, finally, into carbon-carbon aircraft brake discs.

The U.S. sought a rehearing of the trade court's decision, arguing that Barnett should have performed a GRI 2(a) analysis, which says any reference in a heading to "an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article."

The government said while the court addressed GRI I and 3(a) in its previous decision, it "failed to make an explicit finding with respect to whether the segments are finished parts or unfinished parts, and if they are unfinished, whether the segments have the essential character of a finished aircraft part."

Barnett said this case is unlike other classification cases "involving parts of articles," since the segments at issue "appear to share characteristics of both parts and raw materials." The segments are like parts, since they are "dedicated for use in, and are integral to, the manufacturing of needled preforms and, ultimately, aircraft brake discs." The segments are also like raw materials, since they are "imported upstream in the production process before undergoing substantial post-importation processing, including a change at the molecular level, resulting in several identifiable (intermediate) articles before the final product," the court said.

Previously, the court said the segments are finished parts and not raw materials, and while there's no reason to "reconsider that decision," that's not the end of the inquiry, Barnett said.

"The needled preforms are not a finished 'part' of an aircraft," the court held, adding that a "finished" good is one that's "suitable for its ultimate 'intended use.'" While an aircraft brake disc may be classified as "a part of an aircraft braking system and, in turn, a part of an aircraft," the needled preforms aren't finished because the preforms aren't "suitable for their intended use and, instead, must undergo substantial additional processing."

Barnett said it's true the segments are "identifiable to the downstream article," namely the brake discs, and are used for no other purpose. However, it's also true that recognizing the imports are parts isn't precluded just because "the article of which the import is a part undergoes further processing provided the import meets the requirements for classification as a part, is not mere material for a part, and is not excluded by operation of the section and chapter notes." But meeting the requirements for a part requires an item to be a "finished part or to meet the requirements for an unfinished part pursuant to GRI 2(a) when the terms of the relevant heading expressly include parts."

Ultimately, the court said the imported segments must be found to be finished parts in relation to the interim article, which the court previously found, and the interim article also must be found to constitute a finished part in relationship to the final downstream product. Barnett said he erred in failing to apply this framework to the parts at issue.

Applying the framework now, Barnett noted that Honeywell didn't make any argument that the needled preform is a "finished part." Instead, Honeywell said a needled preform can be considered a "blank," classifiable as an "unfinished aircraft brake disc pursuant to GRI 2(a)." Explanatory Note II to GRI 2(a) says the rule applies to "blanks unless these are specified in a particular heading."

Barnett said that since terms of GRI 2(a) alone aren't enough to classify the needled preforms as a finished aircraft part, the court must address whether the needled preforms are "blanks."

The judge ultimately said they aren't, first defining a "blank" as an "article, not ready for direct use, having the approximate shape or outline of the finished article or part, and which can only be used, other than in exceptional cases, for completion into the finished article or part."

The court said the "concept of a blank applies to a type of intermediate product that is imported, perhaps en masse, for final finishing operations particular to the desired end product." Barnett said this understanding of a blank is in line with at least one dictionary definition that defines a blank as “a piece of material prepared to be made into something (as a key) by a further operation.”

Here, the needled preforms aren't "blank" aircraft brake discs ready to be processed into the "desired size and shape" of an aircraft brake disc, the court held. Instead, the needled preforms "must first undergo a days-long molecular change while being processed into a carbonized preform, after which a months-long densification process converts the carbonized preform into a densified carbon-carbon preform." These extensive processes aren't akin to the type of finishing processes applied to blanks, the court said.

Since the needled preforms aren't classifiable as a part of aircraft brake discs, "neither are the segments, regardless of the fact they may be considered parts of the needled preform," the court said.

(Honeywell International v. United States, Slip Op. 25-146, CIT # 17-00256, dated 11/25/25; Judge: Mark Barnett; Attorneys: William Randolph Rucker of Faegre Drinker for plaintiff Honeywell International; Edward Kenny for defendant U.S. government)