CLA-2-83:OT:RR:NC:N1:121
Mr. Daniel Cannistra
Crowell and Morning
1001 Pennsylvania Ave
Washington, DC 20004
RE: The tariff classification of a bearing with an integral shaft from Japan
Dear Mr. Cannistra:
In your letter dated April 17, 2010, you requested a tariff classification ruling on behalf of Aisin Holdings of America, Inc.
The merchandise under consideration is described as a bearing with an integral shaft. It consists of polished steel balls positioned between a steel outer race and a steel stem. The stem is an integral round shaft which is grooved at one end to serve as the inner race of the bearing and extends beyond the face of the bearing to facilitate mounting of the bearing in a suitable fitting. The integral shaft bearing has an outside diameter of 15.5 mm. This component is suitable for use solely with Aisin’s automobile door roller assemblies. It is used in conjunction with other fittings to allow the vehicle door to open and close.
Your letter indicates that you believe the instant bearings are appropriately classified in subheading 8482.10.1040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for ball bearings with integral shafts having an outside diameter not over 30 mm. This office disagrees with your assertion. The bearing with integral shaft meets the terms of heading 8302, HTSUS, since it is a mounting/fitting used on motor vehicles. Explanatory Note 83.02 states the following, "This heading covers general purpose classes of base metal accessory fittings and mountings, such as are used largely on furniture, doors, windows, coachwork, etc. Goods within such general classes remain in this heading even if they are designed for particular uses (e.g., door handles or hinges for automobiles)." Accordingly, the subject bearings are classified in heading 8302, HTSUS, and are determined to be "parts of general use" as defined in Section XV, Note 2. Parts of general use are precluded from classification within Section XVI, which covers chapters 85 and 84, per Note 1(g) to Section XVI.
The applicable subheading for the bearing with an integral shaft will be 8302.30.3060, HTSUS, which provides for base metal mountings, fittings and similar articles, other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof, of iron or steel, of aluminum or of zinc, other. The rate of duty will be 2 percent ad valorem.
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 Barbara Kaiser at (646) 733-3024.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division