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NY 867992

November 12, 1991

CLA-2-84:S:N:N1:102 867992


TARIFF NO.: 8482.10.5048; 8483.50.8040

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 such you contend that they should take the tariff classification for parts of the equipment that they are parts of. The items involved are as follows:

1) part number SFT20 (sample # 20), a plastic single row radial ball bearing used as a shaft support for a roller. The outer race of the bearing is molded into an integral flange mounting, complete with two bolt holes.

2) part number AIB62023,5P (sample #23), a plastic grooved pulley with ball bearing core. This part is designed for use on gym exercise equipment that utilize 3/16" wire.

3) part number AC4P28 (sample # 25), a plastic grooved pulley with ball bearing core. You specify that this part has varied applications , but in the instant situation, it was designed for use with greenhouse doors.

4) part number ACSMW30PGC/2N/G (sample #27), a metal and plastic wheel consisting of a flanged outer plastic tire, a solid metal inner ring with rivet fastener, and antifriction steel balls held in a retainer. The unit is installed in a four wheel track roller used in manually operated overhead track lighting conveyor systems. Without a cost of materials breakdown for the plastic and metal components, we are unable to presently classify this item.

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 part #SFT20 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 AIB62023,5P and AC4P28 will be classifiable under 8483.50.8040, HTS, which provides for grooved pulleys. The duty rate will be 5.7 percent ad valorem.

It is the opinion of this office that part number SFT20 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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