NY 861287

APR 04 1991


CLA-2-84:S:N:N1:102 861287

Ms. Shari Smith
Tente Casters, Inc.
P.O. Box 18638
1211 Cox Avenue
Erlanger, Kentucky 41018

RE: The tariff classification of needle roller bearings, antifriction steel balls, and inner rings for ball bearings from Germany

Dear Ms. Smith:

In your letter dated March 6, 1991 you requested a tariff classification ruling. Your inquiry deals with specific imported components used in the production of casters and wheels. All of these items are some form of antifriction bearing or parts of such bearings. With your letter you provided us with samples and labelled them "I" to "M". Sample "I" is called a ball scale (DAK 050). This is the inner race that is pressed into a wheel body and functions as the bearing surface upon which antifriction steel balls will rotate. Samples "J". "K", and "L" are needle roller bearing inserts. These units consist of a plastic cage, or retainer, fitted with several needle rollers. They are later inserted into the body of a wheel and function as friction reducing elements. Sample "M" consists of two sizes of steel balls, 7/32 and 1/4 inch in diameter. These balls are to be incorporated into the swivel portion of a steel caster.

The applicable subheading for the needle roller bearings, samples "J", "K" & "L", will be 8482.40.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for needle roller bearings. The rate of duty will be 6.5 percent ad valorem. The ball scale, sample "I", is classifiable under the heading covering parts of ball bearings, inner and outer races, HTS item 8482.99.1010. The duty rate will be 11 percent ad valorem. The steel antifriction balls, sample "M", will be classified under 8482.91.0010, which provision covers parts of ball bearings, steel alloy balls. The duty rate is 4.9 percent ad valorem. It is the opinion of this office that the three models of needle roller bearings would not be subject to antidumping duties under the current Department of Commerce antifriction bearing dumping investigation, as published in the Federal Register on May 15, 1989. The grounds for this determination are that we would consider this to be covered under the exclusion for needle roller bearings. On the other hand, the ball scale and the steel balls would be covered by the dumping order under the category of "parts of ball bearings". Please contact your local port for the applicable case number and current dumping margins. Should you desire a binding ruling on the applicability of this ADA case to your merchandise, please write directly to the Department of Commerce, Office of Compliance, Washington, D.C.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport