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NY 867991

November 12, 1991

CLA-2-84:S:N:N1:102 867991


TARIFF NO.: 8482.10.5044; 8482.10.5048; 8483.40.9000

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, such as parts of printers, medical laboratory equipment, and roof turbines. 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 CM8HSGWTN/2N/D (sample # 15), a plastic, single row radial ball bearing with a flange shaped outer ring that contains two mounting holes. The part is used to support a roller, which in turn supports bottles used to grow laboratory cultures.

2) part number AC 85 M 254 TLCU (sample # 16), a plastic, single row radial ball bearing with an outer ring incorporating molded-in mounting clips (integral fixing lugs). The part is used to support a wind driven turbine in a house ventilation system.

3) part number AC82SP321DR (sample # 17), a plastic drive gear with splined inner core, containing two support ball bearings mounted on either side of the main gear shaft. This part is designed for use in paper handling systems (tractor) on impact printers.
4) part number AC82SP472TP (sample # 18), a plastic drive gear with splined inner core and single support bearing pressed onto one side of the gear shaft. As in the case of sample #16, the outer ring of the bearing has integral fixing lugs into order to facilitate the assembly of this component into the paper handling (tractor) system of an impact printer.

5) part number AC825SP472FL (sample # 19), a plastic, single row radial ball bearing with an outer ring incorporating molded-in mounting clips (integral fixing lugs) and a splined inner ring. The part is designed to support a drive shaft in a paper handling system (tractor) on an impact printer.

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 5 above are clearly ball bearings and are to be classified accordingly. Items 3 and 4 are gears and classifiable as such.

The applicable subheading for part #CM8HSGWTN/2N/D will be 8482.10.5048, Harmonized Tariff Schedule of the United States (HTS), which provides for single row radial ball bearings, having an outside diameter of over 30 mm but not over 52 mm. The rate of duty will be 11 percent ad valorem. Parts number AC85M254TLCU and AC82SP472TP will be 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 gears, part numbers AC82SP321DR and AC82SP472TP, will be 8483.40.9000, HTS, which provides for gears and gearing, other than toothed wheels, chain sprockets and other transmission elements entered separately. The duty rate will be 2.5 percent ad valorem.

It is the opinion of this office that parts # CM8HSGWTN/2N/D, AC85M254TLCU and AC82SP472TP 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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