CLA-2-87:RR:NC:MM:101 F88005

Ms. Connie Hagarman
Atty. In Fact
The A.W. Fenton Company, Inc.
1157 Rarig Avenue
Columbus, Ohio 43219-2357

RE: The tariff classification of an Outboard Retainer, a Steel Circlip, a Retaining Ring, a Roller B Forging, a Holder Forging, and a Needle Roller from Japan

Dear Ms. Hagarman:

In your letter dated May 31, 2000 you requested a tariff classification ruling on behalf of your client Honda Trading America Corporation.

You submitted tagged samples as well as drawings and pictures of these items to demonstrate how they are used together.

You state that all the items included in this request are made of steel. Item A is an Outboard Retainer, which is a roller/holder. It will be imported as a solid piece and the holes will be made in the U.S. It will be used in the universal joint on the outboard side of the drive shaft. The following pieces will be used in the universal joint on the inboard side of the drive shaft.

Item B is a Steel Circlip. Item C is a Retaining Ring used to hold the rollers in place. Item D is a Roller B Forging. This item will be further manufactured in the U.S. prior to use. Item E is Holder Forging. Item F is Needle Roller. The Rollers are mounted between the holder forging (inside) and the Roller B Forging (outside). You state that this assembly will ensure the plunging characteristic of the universal joint with high axial freedom.

The applicable subheading for the Steel Circlip will be 7318.24.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers… and similar articles, of iron or steel: Non-threaded articles: Cotters and cotter pins. The rate of duty will be 3.8% ad valorem. The applicable subheading for the Needle Roller will be 8482.91.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for Ball or roller bearings, and parts thereof: Parts: Balls, needles and rollers…Needles. The rate of duty will be 4.4% ad valorem.

The applicable subheading for the Outboard Retainer, Retaining Ring, Roller B Forging, and Holder Forging will be 8708.99.6700, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other parts for power trains. The rate of duty will be 2.5% ad valorem.

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 Robert DeSoucey at 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division