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HQ 961489

JULY 28, 1998

CLA-2 RR:CR:GC 961489 JAS


TARIFF NO.: 8482.10.50

Port Director of Customs
150-A West Phillips Road
Greer, SC 29650

RE: I.A. 5/98; Rail Roller Bearing; Cam Follower Used in Guiding Machinery Parts; Parts of Plastic Film Stretching Machine; Pivot Bearing, Heading 8482; Parts of Machinery for Working Rubber or Plastics, Heading 8477; THK America, Inc. v. United States; T.D. 94-22; Section XVI, Note 2, HTSUS

Dear Port Director:

This is our decision on Internal Advice 5/98, initiated by a letter to you on behalf of Bruchner, Inc., from the importer's representative, dated February 12, 1998. The issue is the classification under the Harmonized Tariff Schedule of the United States (HTSUS), of rail roller bearings, products of Germany. Four (4) samples were submitted.


The submitted samples, parts 530256.10, 530256.11, 530256.12 and 530256.13, are referred to variously as rail rollers, pivot bearings and cam followers. In a purchase order, dated February 28, 1996, the German supplier identifies them as "rail roller bearings." Each measures between 1 1/4 and 1 1/8 inch in diameter and incorporates a double row of steel balls as rolling elements, between an inner ring or race, and a significantly thicker outer ring or race. Three have threaded mounting studs and one incorporates a shaft with a bored hole at the end, all measuring 3/4 to 1 1/2 inch long.

These articles are said to be parts for a plastic film stretching machine, and were entered in 1996 under a provision in HTS heading 8477 for machinery for working rubber or plastics. Because the importer preliminarily advised that these articles were pivot bearings, you propose to reclassify them as bearings
of HTS heading 8482. The internal advice applicant supports the heading 8477 classification on the basis that these articles are not used in anti-friction applications; rather, they are cam followers used for guiding another piece along a guide rail.

The provisions under consideration are as follows:

8477 Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in [chapter 84]; parts thereof:

8477.90 Parts:

8477.90.80 (now 85) Other

8482 Ball or roller bearings, and parts thereof:

8482.10.50 Other


Whether the described articles are goods of heading 8482.


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.

We agree with the internal advice applicant's contention that the articles under consideration function as cam followers. Cams mounted on a rotating shaft in the film stretching machine cause the articles in issue to move in a plane that supports loads perpendicular to the mounting stud. In devices such as cam followers, the outer ring or race is significantly reinforced in thickness to provide weight-carrying capability and permit it to roll on a track. This ring or race is machined internally to create the smooth, precisioned raceway needed to reduce friction during movement. Thus, articles that can both hold and guide moving machine parts as well as reduce friction during such
movement have been held to be bearings of heading 8482. See THK America, Inc. v. United States, 17 CIT 1169 (1993). In fact, in terminology developed by the Anti-Friction Bearing Manufacturers Association, Inc., sanctioned by the American National Standards Institute, the term cam follower equates to the term track roller which is defined as "a radial rolling bearing with a heavy section outer ring, intended for use as a roller to roll on a track, e.g., a cam track". Track rollers may be designed to support radial, axial or combined radial and axial loads. It has been Customs position that cam followers and similar articles are commercially recognized as ball or roller bearings and, thus, are provided for in heading 8482. See T.D. 94-22, published in the Federal Register on March 22, 1994 (59 FR 13450).

Goods that are identifiable parts of machines or apparatus of Chapters 84 and 85 are classifiable in accordance with Section XVI, Note 2, HTSUS. Parts that are goods included in any heading of Chapter 84 or Chapter 85 are in all cases to be classified in their respective headings. See Note 2(a). Other parts are to be classified with the machine or machines with which they are solely or principally used. See Note 2(b). Notwithstanding the internal advice applicant's parts claim, the rail rollers are goods included in heading 8482 for the reasons discussed.


Under the authority of GRI 1, the rail rollers are provided for in heading 8482. They are classifiable in subheading 8482.10.50, HTSUS.

You should mail this decision to the internal advice applicant, through its representative, no later than 60 days from the date of this letter. On that date the Office of Regulations and Rulings will take steps to make the decision available to Customs personnel via the Customs Rulings Module in ACS and to the public via the Diskette Subscription Service, the Freedom of Information Act, and other public access channels.


John Durant, Director
Commercial Rulings Division

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