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NY B85872

June 20, 1997

CLA-2-84:RR:NC:1:102 B85872


TARIFF NO.: 8482.50.0000

Ms. Marilyn-Joy Cerny
Global Customs & Trade Specialists, Inc.
Milltown Office Park - Suite B-202
Brewster, New York 10509

RE: The tariff classification of a three ring bearing assembly from Germany.

Dear Ms. Cerny:

In your letter dated May 16, 1997 you requested a tariff classification ruling on behalf of your client MAN Roland.

The item in question is identified as a "three ring housed bearing assembly". The information provided indicates that the bearing assembly is used to support the rotating cylinders of printing presses and is specially designed to meet the needs of the printing industry. A sample of the bearing assembly and descriptive literature were submitted.

The primary components of the assembly are a steel outer ring, a set of needle rollers, a steel cylinder with an off-center bore and several smaller holes drilled into its sides, a set of cylindrical rollers, and a steel inner ring. The outer ring contains the needle rollers and the bored cylinder. The bored cylinder contains the cylindrical rollers and the inner ring . You indicate the smaller holes drilled into the sides of the bored cylinder permit mounting the bearing assembly onto the printing press.

In your request you refer to the bored cylinder as a "ring-shaped shell or housing" which houses the roller bearings and provides the means by which the bearing assembly can be fixed to the printing press. It is your position that the bearing assembly is a housed bearing, provided for in subheading 8483.20.8080 of the Tariff Schedule of the United States (HTSUS), which provides for housed bearings, incorporating ball or roller bearings. We disagree.

In a housed bearing, the housing is separate and distinct from the bearing which its is designed to incorporate. Housings are designed to simply hold bearings which are, in and of themselves, complete and fully functional.

Within the geometry of the three ring bearing assembly, the outer circumference of the bored cylinder, together with the inner circumference of the outer ring, actually provides the rolling track for the needle rollers. In addition, the inner circumference of its off-center bore, together with the outer circumference of the inner ring, serves as the rolling track for the cylindrical rollers. The bored cylinder serves as both an inner and an outer race.

Thus, the bored cylinder is not a discrete housing, but an integral part of the bearing, without which the bearing could not function. Accordingly, the bearing assembly cannot be classified in HTSUS heading 8483 as a housed bearing.

The applicable subheading for the three ring bearing assembly will be 8482.50.0000, HTSUS, which provides for other cylindrical roller bearings. The rate of duty will be 6.1 percent ad valorem.

It is the opinion of this office that the three ring bearing assembly would be subject to anti-dumping margins under current Department of Commerce orders relating to cylindrical roller bearings. Please contact your local port for the specific margins and the associated dumping case numbers. If you desire a formal determination regarding the applicability of dumping to your products, please write directly to the Office of Compliance, Department of Commerce, Washington, D.C.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Kenneth T. Brock at 212-466-5493.


Robert Swierupski
Chief, Metals and Machinery Branch

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