CLA-2-84:S:N:N1:102 854412

Mr. Brian D. Gill
All Freight Inc.
1200 South 192nd Street
Suite 100
Seattle, WA 98148

RE: The tariff classification of universal joint assemblies from Japan

Dear Mr. Gill:

In your letter dated July 13, 1990, on behalf of your client, RBJ Corp., you requested a tariff classification ruling.

In your letter you state that the item in question, which is invoiced as a "universal joint assembly", has additional characteristics which would require that it be classified in a Harmonized Tariff Schedule provision other than the one specifically covering universal joints. The device, of which a sample was submitted, consists of two bearing cross pieces, which are normally found in universal joints, that are joined together by a steel flange mounted between them. Two of the four spokes of each cross piece are pressed into mounting blocks (small pillow block-like devices) which in turn allow the cross pieces to be bolted to the connecting flange. On the other two spokes of the cross pieces there are yoke-type blocks, each of which has two drilled holes. These holes appear to be designed for mounting the joint assembly to either a transmission shaft or a steering linkage.

Your inquiry describes these universal joint assemblies as being designed for use in earth moving equipment, specifically, front end loaders. You also go on to assert that a normal universal joint "will allow for flexibility and change of linear direction in the drive chain" and that " the subject assembly, because of the connector between the two joints, actually allows for linear transmission in addition to the specific function of the universal joint." In this we disagree. A universal joint, in simplest terms, is a flexible shaft coupling. While there are a number of different designs, they all share one common feature: they allow the transmission of rotational torque between two non- permanently aligned shafts. While the instant item may have a different construction design which would give it greater flexibility, it does not possess features which would make it more than a universal joint.

The applicable subheading for the universal joint assembly will be 8483.60.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for clutches and shaft couplings (including universal joints). The rate of duty will be 5.7 percent ad valorem.

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