CLA-2-73:RR:NC:1:117 D88328
Ms. Karin Bogue
Komatsu America International Company
Parts Division
108N. Industrial drive
Caller# 2101
Ripley, TN 38063
RE: The tariff classification of track chain from Poland and Italy.
Dear Ms. Bogue:
In your letter dated February 15, 1999 you requested a tariff classification ruling.
The item you plan to import is track chain for bulldozers and other earth moving machinery. This chain, which measures over 50 mm, is designed to go around the sprocket of the final drive in the rear of the machine and the front idler. From the documentation and pictures submitted with your request, this merchandise appears to be a cast iron chain which is comprised of a series of links, pins, and bushings. Once imported, each link of the chain will be fitted to a track shoe. As the chain rotates, the shoes are the platform on which the machine rolls.
In your letter you suggest classification under either 7315.11 as roller chain or 7315.12 as other chain. You also make reference to the term articulated. Simply stated articulated means segments united by joints such as pins. This term may be applied to chains classified in both of these subheadings. While the subject merchandise is clearly an articulated chain, it cannot be considered a roller chain as it contains no rollers.
The applicable subheading for the track chain will be 7315.12.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for chain and parts thereof, of iron or steel, articulated link chain and parts thereof,cast and combination chain. The general rate of duty will be free.
Also in your letter, you address the classification of individual track links. Individual links of the subject track chain are to be considered parts of articulated link chain and are specifically provided for in Subheading 7315.19. Any
questions regarding Heading 8431 as it applies to bulldozers and other earth moving machinery should be directed to National Import Specialist Patrick Wholey at 212-637-7036.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Paula Ilardi at 212-637-7016. Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division