CLA-2-84:RR:NC:1:102 E80143

Mr. Changsen Wan
Chinia Machinery Int’l Corporation
27352 Mondano Drive
Mission Viejo, CA 92692

RE: The tariff classification of unfinished bearing rings from China.

Dear Mr. Wan:

In your letter dated April 6,1999 you requested a tariff classification ruling on behalf of Chinia Machinery.

The items in question are an unfinished inner and outer rings for ball bearings. Descriptive information and samples of unfinished and finished rings were submitted.

The inner and outer rings are machine turned blanks which will be further processed after importation and used in the production of ball bearings. Further processing will include heat treatment to impart surface hardness, grinding and honing to achieve desired finish.

The classification of the unfinished rings under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1 provides that classification shall be determined according to the terms of the tariff headings and any relative section or chapter notes. Heading 8482, HTSUS, provides for ball and roller bearings, and parts thereof. GRI 2(a) extends the scope of heading 8482 to include unfinished parts, provided the unfinished parts have the essential character of the finished parts. Examination of the submitted samples reveals that the unfinished rings are net shape blanks which closely approximate the outline of the finished article they will form. Although the rings may not be to final tolerance and may lack the highly polished surfaces of finished races, upon importation they will possess the unique geometry which makes them readily recognizable as inner and outer rings for ball bearings. Further, the unfinished rings have no other practical use other than for completion into finished rings for ball bearings. We find that the subject rings are unfinished articles which have the essential character of the finished rings and races provided for in HTSUS heading 8482.

The applicable subheading for the unfinished rings will be 8482.99.0500, HTSUS, which provides for inner or outer rings or races for ball bearings. The general rate of duty will be 9.9 percent ad valorem.

It is the opinion of this office that the unfinished rings are not subject to antidumping duties because parts of ball bearings originating from China are not within the scope of current orders of the Department of Commerce relating to antifriction bearings. Should you desire a binding ruling on the applicability of dumping orders 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 Part 177 of the Customs Regulations (19 CFR 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 Kenneth T. Brock at 212-637-7026.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division

Basic ruling letter 1-6-97 version