CLA-2-87:OT:RR:NC:N2:206
Paul Michael Turay
OEC Group
11960 Westline Industrial Drive, Suite 350
St. Louis, MO 63146
RE: The tariff classification of clutch release bearings from China
Dear Mr. Turay:
In your letter dated November 29, 2018, you requested a tariff classification ruling on behalf of your client, Platinum Driveline, Inc. of Eureka, Missouri. Descriptive literature and pictures were provided with your request.
You have identified in your letter the items under consideration as Clutch Release Bearings, part numbers RCB6012, RCB6014, RCB6016, RCB6018, and RCB6020. However, you provided pictures and information on clutch release bearings, part numbers RCB6205-PL, RCB6180, RCB6198, RCB6123, and RCB6256. This office has made a determination on the latter five clutch release bearing part numbers.
All five clutch release bearings are designed for use in passenger vehicles. When the clutch pedal is depressed, the release bearing moves toward the flywheel, pushing in the pressure plate’s release fingers, and moving the pressure plate fingers or levers against the pressure plate spring force.
Clutch release bearings, part numbers RCB6123 and RCB6180, are described as radial ball bearings that consist of a race and a cage that contains ball elements. Part numbers RCB6198 and RCB6205-PL consist of two races and a cage containing ball bearings. Part numbers RCB6205-PL, RCB6198, and RCB6123 are made of steel and part number RCB6180 is made of steel and plastic.
Part number RCB6256 is a clutch release radial ball bearing, which consists of two races and a cage with the ball elements, and sleeves to install on the shaft and clips to retain on the clutch fork. The assembly is composed of steel, and based on the pictorial diagrams submitted, it appears to contain the clutch fork.
The applicable subheading for the Clutch Release Bearings, Item Numbers RCB6123, RCB6180, RCB6198, and RCB6205-PL, will be 8482.10.5008, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Ball or roller bearings, and parts thereof: Ball bearings: Other: Other: Thrust bearings.” The general rate of duty will be 9 percent ad valorem.
The applicable subheading for the Clutch Release Bearing, Item Numbers RCB6256, will be 8708.93.7500, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Clutches and parts thereof: For other vehicles: Clutches: Other.” The general duty rate will be 2.5 percent ad valorem.
Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.
Products of China classified under subheadings 8482.10.5008 and 8708.93.7500, HTSUS, unless specifically excluded, are subject to the additional 25 and 10 percent ad valorem rate of duty, respectively. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8482.10.5008, HTSUS and 9903.88.03, in addition to subheading 8708.93.7500, HTSUS, listed above.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 https://hts.usitc.gov/current.
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, please contact National Import Specialist Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division