CLA-2-84:OT:RR:NC:N1:106

Mr. Jorge Torres
Interlink Trade Services
10601 S. Jackson Rd.
Suite 200
Pharr, TX 78577

RE: The tariff classification of roller ball transfer unit parts from Mexico.

Dear Mr. Torres:

In your letter dated September 25, 2009 you requested a tariff classification ruling on behalf of your client Roller Bearing Company of America, Inc. Information and diagrams were sent with your request.

The device in question is an EverGlide T-Ball. The device consists of a zinc-nickel plated cup in which small steel balls are placed. On top of these rests a single large steel ball and the entire assembly is held together with a plastic retainer ring. After importation, these devices are inserted into the deck of a roller ball transfer unit. The roller ball transfer unit allows horizontal movement of large loads, in any direction, with minimum effort. The roller ball transfer units are often used on loading and unloading machinery for shipping and are sometimes used in the decks of aircraft cargo holds.

You suggest that the EverGlide T-Ball would be correctly classified in 8431.31.0010 Harmonized Tariff Schedule of the United States (HTSUS). This is not correct. This subheading does not exist and would, if it did exist, be for parts of passenger and freight elevators, skip hoists and escalators of which the roller ball transfer unit is not.

The applicable subheading for the EverGlide T-Ball will be 8431.39.0010, HTSUS, which provides for parts suitable for use solely or principally with the machinery of headings 8425 to 8428: of machinery of heading 8428: other, of elevators and conveyors. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Mark Palasek at (646) 733-3013.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division