CLA-2-84:S:N:N1:102 867992
Mr. Robert S. Smith
McGuire, Woods, Battle & Boothe
The Army and Navy Club Building
1627 Eye Street N.W.
Washington, D.C. 20006
RE: The tariff classification of assorted plastic components
from England
Dear Mr. Smith:
In your letter dated October 2, 1991, on behalf of your U.S.
client, IABC, you requested a tariff classification ruling.
In your original inquiry you stated that the sampled parts
submitted were all for use in specific applications. As such you
contend that they should take the tariff classification for parts
of the equipment that they are parts of. The items involved are
as follows:
1) part number SFT20 (sample # 20), a plastic single row
radial ball bearing used as a shaft support for a roller.
The outer race of the bearing is molded into an integral
flange mounting, complete with two bolt holes.
2) part number AIB62023,5P (sample #23), a plastic grooved
pulley with ball bearing core. This part is designed for
use on gym exercise equipment that utilize 3/16" wire.
3) part number AC4P28 (sample # 25), a plastic grooved
pulley with ball bearing core. You specify that this part
has varied applications , but in the instant situation, it
was designed for use with greenhouse doors.
4) part number ACSMW30PGC/2N/G (sample #27), a metal and
plastic wheel consisting of a flanged outer plastic tire, a
solid metal inner ring with rivet fastener, and antifriction
steel balls held in a retainer. The unit is installed in a
four wheel track roller used in manually operated overhead
track lighting conveyor systems. Without a cost of
materials breakdown for the plastic and metal components, we
are unable to presently classify this item.
While it may be that the above parts are specifically
designed for use only as components of a larger system, that fact
does not override the directives in the General Rules of
Interpretation (GRI's) to the Harmonized Tariff Schedules (HTS)
of the United States. The GRI's stipulate that a "part" of an
article, which itself is specifically provided for in one of the
subheadings of the HTS, must be classified within that "eo
nomine" provision before being considered a "part" of the overall
device. Items 1, 2 and 3 above are clearly ball bearings and are
to be classified accordingly.
The applicable subheading for part #SFT20 will be
8482.10.5048, Harmonized Tariff Schedule of the United States
(HTS), which provides for single row radial ball bearings, having
an outside diameter of over 30 mm but not over 52 mm. The rate
of duty will be 11 percent ad valorem. Parts number AIB62023,5P
and AC4P28 will be classifiable under 8483.50.8040, HTS, which
provides for grooved pulleys. The duty rate will be 5.7 percent
ad valorem.
It is the opinion of this office that part number SFT20
would not be subject to antidumping duties under the current
Department of Commerce antifriction bearing dumping
investigation, as published in the Federal Register on May 15,
1989. Thermoplastic bearings were specifically excluded from the
scope of this investigation. Should you desire a scope
determination on the applicability of this ADA case to your
merchandise, please write directly to the Department of Commerce,
Office of Compliance, Washington, D.C.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport