CLA-2-84:S:N:N3:102 887770

Mr. Ernesto Zapata
Corcoran International Corp.
147-05 New York Blvd.
Jamaica, N.Y. 11434

RE: The tariff classification of automotive wheel bearing kits, clutch release bearings from Germany

Dear Mr. Zapata:

In your letter dated June 28, 1993, on behalf of your client, North American Marketing Enterprises, Inc., you requested a tariff classification ruling.

The articles involved in this request consist of five different models of automotive wheel bearing kits (5100S, 5101S, 5103S, 5105S, & 5112S), as well as a model EVR # 1004 clutch release bearing. Each of the wheel bearing kits consists of at least one, and in most cases, two tapered roller bearings, along with an assortment of seals, caps, retaining rings and spacers. It is our opinion that the essential character of these sets is the tapered roller bearings. The clutch release bearing consists of an angular contact thrust ball bearing mounted onto a phenolic resin carrier. It is used in the clutch assembly of the automobile.

The applicable subheading for the five wheel bearing kits will be 8482.20.0030, Harmonized Tariff Schedule of the United States (HTS), which provides for tapered roller bearings, cup and cone assemblies entered as a set. The rate of duty will be 6.5 percent ad valorem. The clutch release bearing will be classifiable under HTS number 8482.10.5068, other ball bearings, other. The rate of duty will be 11 percent ad valorem.

It is the opinion of this office that the clutch release bearing would be subject to anti-dumping (ADA) margins under the current Department of Commerce ADA findings on bearings, as published in the Federal Register on May 15, 1989. Please contact your local port for the specific case numbers and percentages for each case. If you desire a scope determination on the applicability of anti- dumping duty to your product, please write directly to the Office of Compliance, Department of Commerce, 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