CLA-2-84:S:N:N3:102 891868
Mr. Michael A. Kelly
Global Precision Trade, Inc.
66 Forty Acre Mt. Road
Danbury, CT 06811
RE: The tariff classification of cylindrical rollers for drilling
bits from Italy
Dear Mr. Kelly:
In your letter dated October 22, 1993 you requested a tariff
classification ruling.
The cylindrical shaped rollers involved in this request are
manufactured from a special type of steel known as "solar". They are used
as friction-reducing elements inside steerable motor rock bits sold to the
oil and gas exploration industry. It is important to note the design and
construction of these bits and the location of the bearing race surfaces.
Each bit consists of three rotating inserts. The inserts (cones) have
machined races cut into their interior surfaces. Likewise the
corresponding shaft of the bit has three equally machined journal surfaces
onto which these inserts are mounted. The rollers are placed, without
retaining cages, between the journal and cone. In effect the manufacturer
of the rock bit uses existing metal surfaces to act as the inner and outer
races of the bearing. Since the rollers are imported loose, and since it
is impossible to extract a separately distinguishable bearing (inner and
outer race, rollers and cage), we would not view these rollers as parts of
bearings.
The applicable subheading for the cylindrical rollers will be
8207.12.3090, Harmonized Tariff Schedule of the United States (HTS), which
provides for interchangeable tools for handtools, whether or not power-
operated, or for machine-tools: rock drilling or earth boring tools and
parts thereof: with working parts of other material, and parts thereof:
with cutting part containing by weight over 0.2 percent of chromium,
molybdenum, or tungsten or over 0.1 percent of vanadium...other. The rate
of duty will be 7.2 percent ad valorem.
It is the opinion of this office that the instant merchandise 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. The scope of this investigation covers
ball and roller bearings and parts thereof. These rollers do not
constitute parts of "bearings". 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