CLA-2-84:OT:RR:NC:N1:102

Ms. Konnie Gurung
Quality Bicycle Products, Inc.
6400 West 105th Street
Bloomington, MN 55438

RE: The tariff classification of bearing and seal kits from Italy

Dear Ms. Gurung:

In your letter dated June 29, 2011 you requested a tariff classification ruling. Descriptive literature and representative samples were included with your submission. The samples will be returned to you.

The products under consideration are described as Campagnolo Bottom Bracket bearing and seal kits. You state that these kits are designed for exclusive use on bicycles with Campagnolo Ultra Torque cotterless crank sets.

The Campagnolo USB Ultra Torque Bottom Bracket bearing and seal kit, item number CR 9337, consists of silicon nitride (ceramic) ball bearings held in a polyamide retainer fitted to steel races and rubber seals. This bearing measures 6 mm in width and has an outside diameter of 37 mm and an inside diameter of 25 mm.

The Campagnolo CULT Ultra Torque Bottom Bracket bearing and seal kit, item number CR 9336, is comprised of silicon nitride (ceramic) ball bearings held in a polyamide retainer fitted to “cronitect” (nitrogen-treated) steel races and rubber seals. This bearing has an outside diameter of 37 mm, an inside diameter of 25 mm and a width of 6 mm.

The Campagnolo Ultra Torque Bottom Bracket bearing and seal kit, item number CR 9916, consists of steel radial ball bearings held in a polyamide retainer fitted to steel races and rubber seals. This bearing has an outside diameter of 37 mm, an inside diameter of 25 mm and a width of 6 mm.

You suggest classification of the bottom bracket bearing and seal kits under subheading 8714.96.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of … bicycles …: Other: Pedals and crank-gear, and parts thereof: Cotterless-type crank sets and parts thereof.”

Although the kits are, prima facie, bicycle parts, they are nonetheless bearings. The subject ball bearings are specifically provided for in HTSUS headings 6909 and 8482 respectively. In addition, Section XVII, Note 2(e) excludes articles of heading 8482, HTSUS.

The applicable subheading for the Campagnolo USB Ultra Torque Bottom Bracket bearing and seal kit, item number CR 9337, and the Campagnolo CULT Ultra Torque Bottom Bracket bearing and seal kit, item number CR 9336, will be 6909.19.5010, HTSUS, which provides for ceramic bearings. The rate of duty will be 4 percent ad valorem.

The applicable subheading for the Campagnolo Ultra Torque Bottom Bracket bearing and seal kit, item number CR 9916, will be 8482.10.5048, HTSUS, which provides for radial ball bearings, single row, having an outside diameter over 30 millimeters but not over 52 millimeters. The rate of duty will be 9 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/.

The merchandise in question may be subject to antidumping duties or countervailing duties. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection. You can contact them at http://www.trade.gov/ia/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on “Antidumping and countervailing duty investigations”), and you can search AD/CVD deposit and liquidation messages using the AD/CVD Search tool at http://addcvd.cbp.gov/.

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 Kenneth T. Brock at (646) 733-3009.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division