CLA-2-73: OT: RR: NC: N1:113

Ms. Cathy Spencer
Freight Expediters
6920 Engle Rd., Suite II
Middleburg Heights, OH 44130

RE: The tariff classification of work roller guides from China

Dear Ms. Spencer:

In your letter dated February 28, 2019, on behalf of your client Woodcraft Supply LLC, you requested a tariff classification ruling. Samples and pictures of the subject work roller guides were submitted for our review.

The articles under consideration are identified in your letter as work roller guides, part numbers 07B08/165744 for the 1" roller ball guides and 07B09/165743 for the 5/8" roller ball guides. The work rollers are described as ball bearing rollers and are used to move large pieces of lumber or other heavy materials in a workshop. They consist of a steel housing with 5/8" (part number 07B09/165743) or 1" (part number 07B08/165744) hardened steel balls rotating on 1/8" diameter internal bearings. You stated that "The diameter of the small ball is 3/32" and the big ball is 5/8" for part number 07B09/165743. The diameter of the small ball is 1/8" and the big ball is 1" for part number 07B08/165744. The housing has two holes for securing the work rollers to a table, work bench or wooden rails." The marketing material indicates that "Unlike rollers which operate only in a straight line, these 360 degree universal transfer bearings excel where shop materials are pushed and turned in all directions." The user can make up their own outfeed tables for saws, finishing tables, assembly lines, etc.

In your letter, you suggested that the work roller guides be classified within subheading 8482.10.5068, Harmonized Tariff Schedule of the United States (HTSUS), which provides for ball or roller bearings; ball bearings; other; other; other. Our office disagrees, as each work roller guide consists of a housing that includes an anti-friction bearing and a steel ball that rotates and guides items, such as wood. Heading 8482 does not provide for machinery or other articles incorporating ball or roller bearings. As such, the work roller guides are excluded from consideration of HTSUS heading 8482. Therefore, the subject work roller guides would be classified under heading 7326, HTSUS, which provides for other articles of iron or steel.

The applicable subheading for the work roller guides, part numbers 07B08/165744 and 07B09/165743, will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other, other...other. The rate of duty will be 2.9 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

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 subheading 7326.90.8688, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7326.90,8688, 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.

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 Ann Taub at


Steven A. Mack
National Commodity Specialist Division