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NY 867990

November 12, 1991

CLA-2-84:S:N:N1:102 867990


TARIFF NO.: 8482.10.5044; 8482.10.1040

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 specific applications, as parts of photographic developing equipment. As such you contend that they should take the tariff classification for parts of such equipment. The items involved are as follows:

1) part number CM10 (sample # 3), a plastic, single row radial ball bearing. The part is used to support a roller which feeds film into photographic developers.

2) part number CM6DHPP (sample # 6), a plastic, single row radial ball bearing with an outer ring which has been molded into a square shaped mounting. The inner ring has a D- shaped bore designed to accept a "D" shaft in the paper feed mechanism.

3) part number CM8PF70, PAKO CINE (samples # 7 & 8), plastic, integral shaft ball bearings which contain a single row of balls that ride on a hollow shaft. The shafts of both samples are designed in such a way that they mate together, forming a double row, integral shaft bearing. The part is designed for use in rollers for a 70 mm reel used in the processing of 70 mm film.

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, 2 and 3 above are clearly ball bearings and are to be classified accordingly.

The applicable subheading for parts #CM10 and CM6DHPP will be 8482.10.5044, Harmonized Tariff Schedule of the United States (HTS), which provides for single row radial ball bearings, having an outside diameter of 9 mm and over but not over 30 mm. The rate of duty will be 11 percent ad valorem. Parts number CM8PF70, PAKO CINE will be classifiable under 8482.10.1040, HTS, which provides for ball bearings with integral shafts, having an outside diameter not over 30 mm. The duty rate will be 4.2 percent ad valorem.

It is the opinion of this office that the above parts 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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