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

Sina Beheshtaein
22332 Caminito Tecate
Laguna Hills, Califorina 92653

RE: The tariff classification of Tapered Roller Bearings, Single Row Ball Bearings, and Double Row Ball Bearings.

Dear Ms. Beheshtaein:

In your letter dated October 29, 2015, you requested a tariff classification ruling. A representative sample of each bearing assembly was submitted with your request. Based on visual inspection of the samples that were submitted and literature researched from the manufacturer’s website, the first items under consideration are a Timken Tapered Roller Bearing, item number L44643/10, and a Timken Tapered Roller Bearing, item number LM68149/11. Both tapered roller bearings have the same physical features, except for their size. Bearing number L44643/10 measures 50 mm and bearing number LM68149/11 measures 67 mm. The Tapered Roller Bearings consist of a Cup and Cone Assembly containing a single row of tapered rollers as rolling elements. The samples submitted suggest the Tapered Roller Bearings and cups will be entered together as sets and the outside diameter of the cup will not exceed 102 mm.

The next four items under consideration are SKF Single Row Deep Groove Ball Bearings. SKF, item number 6000-2RS1, measures 50.4 mm in diameter and SKF, item number 6204-2RS1, measures 47 mm in diameter. SKF, item number 6205-2RS1, measures 52 mm in diameter. SKF, item number 625-2RS1, measures 16 mm in diameter. Taken from the manufacturer’s website, these Single Row Deep Groove Ball Bearings are constructed with deep, uninterrupted raceway grooves and capped with seals. The raceway grooves are said to have a close osculation with the balls, enabling the bearings to accommodate radial loads and axial loads in both directions.

The last item under consideration is an SKF Double Row Angular Contact Ball Bearing, item Number 3205 A-2RS1TN9/MT33 and it measures 52 mm in diameter. Also, mentioned in the manufacturer’s website, the bearing is constructed of two single row angular contact ball bearings arranged back-to-back. It is said they can accommodate radial loads as well as axial loads in both directions. They provide stiff bearing arrangements and are able to accommodate tilting movements.

Under the authority of GRI 1 and based on all of the information provided, we find the Tapered Roller Bearing Cup and Cone Assemblies, Single Row Ball Bearings, and Double Row Ball Bearings are specifically provided for in heading 8482, Harmonized Tariff Schedule of the United States (HTSUS). As such, the applicable subheading for Timken Tapered Roller Bearing Cup and Cone Assemblies will be 8482.20.0040, (HTSUS), which provides for other tapered roller bearings including cup and cone assemblies entered as a set with cups having an outside diameter not exceeding 102 mm. The rate of duty will be 5.8 percent ad valorem. The applicable subheading for the SKF Single Row Deep Groove Ball Bearings: SKF, item number 6000-2RS1, SKF item number 6204-2RS1, and SKF, item number 6205-2RS1 will be 8482.10.5048, HTSUS, which provides for other single row radial ball bearings having an outside diameter over 30 millimeters but not over 52 millimeters. The general rate of duty will be 9 percent ad valorem. The applicable subheading for the SKF Single Row Deep Groove Ball Bearing that measures16 mm in diameter, SKF, item number 6000-2RS1 will be 8482.10.5044, HTSUS, which provides for other single row radial ball bearings having an outside diameter of 9 mm but not over 30 mm. The rate of duty will be 9 percent ad valorem. The applicable subheading for the SKF Double Row Angular Contact Ball Bearing, item Number 3205 A-2RS1TN9/MT33 5200K bearing will be 8482.10.5028, HTSUS, which provides for other angular contact ball bearings. 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/.

You also are seeking advice on the proper marking and country of origin requirements for the subject bearings.

The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable. In this case, we find that we need additional information to make a marking determination. Please submit the following information. Please indicate the country of origin for each bearing. In which country will each bearing be manufactured or assembled? Provide the country of origin for each component. Submit pictures, photographs and drawings illustrating how the merchandise will be marked.

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 Sandra Martinez at [email protected].

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division