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NY 867989

November 12, 1991

CLA-2-84:S:N:N1:102 867989


TARIFF NO.: 8482.10.5060; 8482.10.5044; 8421.99.0040

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 swimming pool vacuum cleaners exclusively and that, as such they should take the tariff classification for parts of vacuum cleaners. The items involved are as follows:

1) part number CMH 8 MDW (sample # 2), a plastic, double row radial ball bearing with hexagonal shaped opening through the inner ring, used as a cam follower on the propulsion system of the pool cleaner.

2) part number CM 16002 (sample # 5), a plastic, single row radial ball bearing with three slots cut in the inner ring, used to support the rotating turbine.

3) part number D1077 (sample # 22), a plastic hose swivel connector, threaded at one end, with a push on hose connection at the other end. It is used to join the pool cleaner to the water feed hose.

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 and 2 above are clearly ball bearings and are to be classified accordingly.

The applicable subheading for part #CMH 8 MDW will be 8482.10.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for double row radial ball bearings. The rate of duty will be 11 percent ad valorem. Part number CM 16002 is classifiable under 8482.10.5044, HTS, which provides for single row radial ball bearings, having an outside diameter of 9 mm and over but not over 30 mm. The duty rate will be 11 percent ad valorem.

The tariff classification of the plastic hose connector, part number D1077, will be 8421.99.0040, HTS, which provides for other parts of filtering or purifying machinery and apparatus. The duty rate will be 3.9 percent ad valorem.

It is the opinion of this office that parts # CMH 8 MDW and CM 16002 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.


Jean F. Maguire
Area Director

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