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HQ 084535

August 14, 1989

CLA-2 CO:R:C:G 084535 VEA


TARIFF NO.: 7315.11.00

Warren Loewen
General Manager
Loewen Manufacturing
Co., Ltd.
Box 820
Altona, Manitoba

RE: Reconsideration of New York ruling 838496

Dear Mr. Loewen:

Your letter of May 5, 1989, requests reconsideration of a New York ruling dated April 5, 1989 (File 838496), which classified a combine feeder assembly in subheading 7315.11.0020 of the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).


The combine feeder assembly consists of three parts, a roller chain, slats and fasteners. The roller chains are purchased from Japan, Taiwan, or the United States. The slats are made in Canada from Canadian steel, and the fasteners are also purchased from Japan, Taiwan, or Canada. These articles are made of non-alloy steel and are used in a combine feeder assembly, which fits into a combine feeder housing. Combine feeder assemblies are used by farmers, farm machinery dealers, farm stores and farm part distributors in machines that are used to harvest grain.

Each feeder chain is composed of two parallel lengths of roller chain to which are fastened slats at regular intervals. For each feeder chain, the spacing of the slats, as well as the width between the lengths of roller chain is specifically designed for a particular combine model or models. The importer states that the feeder chains can only be used in combines to convey or drag grain away from the cutter assembly of a harvesting combine.

Our New York office classified the feeder chain in subheading 7315.11.0020 as a roller chain of not over 50 mm pitch and containing more than 3 parts per pitch. You disagree with this classification, claiming that these are agricultural products classifiable in heading 8433. You argue that the feeder chain assembly is not a roller chain, because roller chains do not have attachments and are used on a specific model of combine.


Whether feeder chain assemblies are roller chains of iron or steel classified in heading 7315, subheading 7315.11.00; or parts of harvesting or threshing machinery classified in heading 8433, subheading 8433.90.50.


Classification under the HTSUSA is governed by the General Rules of Interpretation (GRIs), the legal principles by which merchandise is classified. GRI 1 states, in part, that the primary consideration in determining whether merchandise should be classified in a heading should be given to the language of the heading and to any relevant chapter or section notes. The headings at issue provide:

7315 Chain and parts thereof, of iron or steel: Articulated link chain and parts thereof:

7315.11.00 Roller Chain

8433 Harvesting or threshing machinery, including straw or fodder balers; grass or hay mowers; machines for cleaning, sorting or grading eggs, fruit or other agricultural produce, other than machinery of heading 8437; parts thereof:

If these articles are classified as roller chains in heading 7315, they are precluded from classification in Section XVI, heading 8433. Note 1(g), Section XVI states that this section does not cover parts of general use, as defined in note 2 to Section XV, of base metal (section XV), or similar goods of plastics (chapter 39). Note 2 to Section XV states that throughout the tariff schedule, the expression "parts of general use" means articles of heading 7307, 7312, 7315, 7317
or 7318 and similar articles of other base metals.

Classification in heading 7315 requires that the article be a chain or a part of a chain. The Explanatory Notes (ENs) for 7315 state that this heading covers chains of cast iron (usually malleable cast iron), wrought iron or steel, regardless of their dimensions, process of manufacture, or in general, their intended use. The merchandise in this case consists of a roller chain and two attachments (slats and fasteners). The argument that this merchandise cannot be a roller chain because the feeder chain in this case has attachments, and normally roller chains do not have attachments, is without merit.

Roller chains do come equipped with attachments. A handbook on chains published by the American Chain Association, Chains for Power Transmission and Material Handling: Design and Applications Handbook, notes in referring to a type of roller chain, a straight sidebar steel fabricated roller chain, that these chains are furnished with a wide variety of attachments, although the types designed for use with flights or slats are probably encountered most often. Thus, not only are some roller chains equipped with attachments, the attachment is often a slat. The slats on a straight sidebar steel fabricated roller chain are mounted over roller pins and eliminate straw and dirt build-up and prevents the chain from stretching. The slats that accompany the feeder chains in this case also perform a similar function. A brochure submitted with the ruling request states that the special slat design of the Loewen replacement feeder chains eliminates the plugging up of your combine by more effectively feeding the material into the cylinder. The American Chain Association Handbook also states that roller chains perform the specific function of conveying. The feeder chains at issue are designed to convey or drag grain away from the cutter assembly of a harvesting combine.

You argue that the completed feeder chain can only be used on a specific model of combine. However, this would not prevent these articles from being classified in heading 7315. According to the ENs for this heading, chains are classified in this heading regardless of their intended use. Since these articles are classified in heading 7315, they are precluded from classification in heading 8433.


Feeder chain assemblies are roller chains of iron or steel classified in heading 7315, subheading 7315.11.00, HTSUSA.


John Durant, Director

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