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HQ 957270

MARCH 3, 1995

CLA-2:CO:R:C:M 957270 JAS


TARIFF NO.: 8482.10.50

Mr. David C. Soto
V. Alexander & Co., Inc.
P.O. Box 291929
Nashville, TN 37229-1929

RE: Unmounted ball bearings; ball bearings and bearing housings imported in the same shipment; housed bearings entered unassembled, subheading 8483.20.80; GRI 2(a), Explanatory Notes; parts of housed bearings, HQ 952850

Dear Mr. Soto:

In your letter of November 2, 1994, on behalf of International Supply, Inc., you inquire as to the tariff classification of unmounted ball bearings from China. A sample bearing mounted in a pillow block or housing was submitted.


You state that ball bearings will either be imported separately, unmounted, or in the same shipment unassembled with bearing housings. You state a particular bearing and its respective housing are assigned specific part numbers and are designed for use only with each other. Each bearing will be assembled in the United States with its corresponding housing and sold as a housed bearing.

You propose to classify the unmounted bearings in subheading 8483.90.70, Harmonized Tariff Schedule of the United States (HTSUS), a provision for parts of articles of subheading 8483.20 (housed bearings, incorporating ball or roller bearings). The tariff status of the bearing housings is not in issue here.

The provisions under consideration are as follows:

8482 Ball or roller bearings, and parts thereof:

8482.10 Ball bearings:

8482.10.50 Other...10.6 percent

8483 ***[b]earing housings, housed bearings and plain shaft bearings; parts thereof:

8483.20 Housed bearings, incorporating ball or roller bearings:

8483.20.80 Other...5.5 percent

8483.90 Parts:


8483.90.70 Parts of articles of subheading 8483.20...5.7 percent


Whether unmounted ball bearings imported in the same shipment with bearing housings are unassembled housed bearings.


Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in accordance with the General Rules of Interpretation (GRIs). GRI 1 states in part that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes, and provided the headings or notes do not require otherwise, according to GRIs 2 through 6. GRI 2(a) states in part that any reference in a heading to an article shall be taken to include a reference to that article entered unassembled or disassembled.

The Harmonized Commodity Description And Coding System Explanatory Notes (ENs) constitute the Customs Cooperation Council's official interpretation of the Harmonized system. While not legally binding on the contracting parties, and therefore not dispositive, the ENs provide a commentary on the scope of each heading of the Harmonized System and are thus useful in ascertaining the classification of merchandise under the System. Customs believes the notes should always be consulted. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (Aug. 23, 1989).

Relevant ENs on the scope of GRI 2(a), p. 2, state under RULE 2(a)...(V) that the second part of Rule 2(a) provides that complete or finished articles presented unassembled or disassembled are to be classified in the same heading as the assembled article. When goods are so presented, it is usually for reasons such as requirements or convenience of packing, handling or transport. - 3 -

The statement in your letter that a particular bearing is designed to be mounted in a specifically engineered bearing housing is not documented in the record. The assigning of part numbers to bearings that purportedly correlate to part numbers for bearing housings is insufficient to establish that they are to be considered unassembled housed bearings. Information before this office indicates that a bearing housing with a particular inner circumference can accommodate a number of bearings having the same outer circumference. For this reason, it is common in the bearing industry to import unmounted bearings and bearing housings, arranging their final configurations after importation based on buyers' individual specifications.

There is no evidence in this case that importing the bearings and bearing housings in the manner indicated has any reasonable relationship to requirements or convenience of packing, handling, or transport. See HQ 952850, dated April 14, 1993, involving similar circumstances in which ball point pen and fountain pen components imported in approximately equal numbers were held to be classifiable as parts rather than as unassembled pens. The method of importation in this case appears designed solely to permit the bearings to receive the lower rate of duty for housed bearings. See T.D. 94-59, (Federal Register, Vol. 59, No. 137, dated July 19, 1994), which reached a similar conclusion with respect to lenses imported with camera bodies.


Ball bearings imported together with bearing housings, as described, are not unassembled articles under GRI 2(a), HTSUS. Under the authority of GRI 1, bearings imported separately, or in the same shipment with bearing housings, are provided for in heading 8482. They are classifiable in subheading 8482.10.50, HTSUS.


John Durant, Director
Commercial Rulings Division

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