CLA-2-74:OT:RR:NC:N1:164
Christopher Ridgway
Miba Industrial Bearings U.S. LLC
1111 Cedar Creek Rd.
Grafton, WI 53024
RE: The tariff classification of a machined copper ring from Germany
Dear Mr. Ridgway:
In your letter dated November 17, 2025, you requested a tariff classification ruling regarding a machined
copper ring from Germany. Technical information was submitted with your request.
The item under consideration is a machined copper ring (Item 151H295-A). As described, it will be used as a
semi-finished component in a thrust bearing assembly for heavy-frame gas turbines in the electric power
generation industry. You state the ring is produced from a copper-chrome alloy forging which undergoes
machining and finishing operations such as the drilling and tapping of holes. Allowing for slight variations,
the ring will feature an outside diameter of 18.19 inches and an inside diameter of 10.69 inches. Additionally,
the ring will measure 1.9 inches in thickness. Based on the submitted information, the machined copper ring
from Germany will undergo significant manufacturing processes after importation into the U.S. including
plating, static pouring, splitting into segments, and machining to remove material and create a precision
bearing surface.
In accordance with General Rule of Interpretation 2(a), you suggest the copper ring is classified within
subheading 8483.30.8090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings and
plain shaft bearings; gears and gearing; ball or roller screws; gear boxes and other speed changers, including
torque converters; flywheels and pulleys, including pulley blocks; clutches and shaft couplings (including
universal joints); parts thereof: Bearing housings; plain shaft bearings: Other: Plain shaft bearings: Without
housing: Other. We disagree.
The ring, as imported, does not have the essential character of a plain shaft bearing. As imported, it possesses
no inherent features, surfaces, or design elements that specifically indicate it will function as a bearing
designed to minimize friction and enhance rotational motion. This item appears to be foundational
component that conceivably may have other uses or applications. It is not until it undergoes a series of
substantial manufacturing processes such as plating, a static pouring process to apply babbitt, machining in
the diameters and faces, drilling, segment splitting, and milling processes that the ring becomes a bearing
featuring a precision bearing surface. Based on these considerations, the subject ring is excluded from
heading 8483.
The applicable subheading for the machined copper ring will be 7419.80.5050, HTSUS, which provides for
“Other articles of copper: Other: Other: Other: Other.” The general rate of duty will be Free.
The duties cited above are current as of this ruling’s issuance. 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
at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(C.F.R.), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 C.F.R. 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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 Paul Taylor at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division