CLA-2-84:RR:NC:1:102 C82045
Mr. Dennis Wilks
Kilian Manufacturing
75 Torlake Cr.
Toronto, Ontario
Canada M8Z 1B7
RE: The tariff classification of unground ball bearings from Canada.
Dear Mr. Wilks:
In your letter you requested a tariff classification ruling on behalf of
Kilian Manufacturing.
The items in question are described as "unground" bearings and identified
by numbers SR-254-9001-66, SR-254-9001-67 and SR-
254-9001-55. Descriptive information, technical drawings and samples were
submitted.
The subject bearings are radial bearings containing a single row of steel
balls which serve as rolling elements. The inner and outer races of the bearing
are machined on multi-spindle automatic screw machines from solid bar stock.
The bar stock is fed into the screw machine where a forming tool shapes and
sizes the outer diameter of the races, while the inner diameter is drilled and
reamed to size. Another forming tool then shapes the single ball track. Once
shaped, the track is then burnished with a burnishing tool to produce the
finished surface on which the rolling elements will roll. To complete the
machining process, a cut-off blade separates the completed race from the bar
stock.
The machined inner and outer races are then subjected to heat treatment and
case hardened to specification and the outer diameter of the outer race is
ground to tolerance, presumably to facilitate mounting. The races are then
washed and ready for assembly with the rolling elements to form a completed
bearing.
Ball and roller bearings are provided for in heading 8482 of the Harmonized
Tariff Schedule of the United States (HTSUS). Subheading 8482.10.5004, HTSUS,
provides for unground ball bearings. The question raised by your request is
whether the grinding of the outer diameter of the outer race precludes treatment
of the subject bearings as unground bearings for tariff purposes.
In our opinion the term "unground bearings" within the context of
subheading 8482.10.5004, HTSUS, refers to ball bearings manufactured with
unground raceways. This opinion comports with our understanding that the raceway
is a critical load bearing surface within a rolling bearing and is the section
of the race which significantly impacts the function of a ball or roller
bearing. Clearly, the design of the raceway is a primary consideration in
realizing the desired operating characteristics of a rolling bearing, and should
merit equal consideration in determining the classification of a bearing for
tariff purposes.
The raceways of the bearings considered here were designed to be burnished,
rather than ground. Burnishing is a finishing process which serves to compress
the surface of the raceway creating a smooth, lustrous finish, with a slight
surface hardness. Unlike grinding, which involves the removal of surface
material by abrasive action, burnishing is effected simply by applying a blunt
tool under pressure to the surface of the raceway.
Accordingly, because the raceways are not ground, we find the subject
bearings to be unground for tariff purposes.
The applicable subheading for the SR-254-9001-66, SR-254-
9001-67 and SR-254-9001-55 ball bearings will be 8482.10.5004, HTSUS, which
provides for unground ball bearings. The general rate of duty will be 9.4
percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs
Regulations (19 CFR 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 Kenneth T. Brock at 212-466-5493.
Sincerely,
Robert Swierupski
Chief, Metals and Machinery Branch
National Commodity
Specialist Division