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NY 891868




November 26, 1993

CLA-2-84:S:N:N3:102 891868

CATEGORY: CLASSIFICATION

TARIFF NO.: 8207.12.3090

Mr. Michael A. Kelly
Global Precision Trade, Inc.
66 Forty Acre Mt. Road
Danbury, CT 06811

RE: The tariff classification of cylindrical rollers for drilling bits from Italy

Dear Mr. Kelly:

In your letter dated October 22, 1993 you requested a tariff classification ruling.

The cylindrical shaped rollers involved in this request are manufactured from a special type of steel known as "solar". They are used as friction-reducing elements inside steerable motor rock bits sold to the oil and gas exploration industry. It is important to note the design and construction of these bits and the location of the bearing race surfaces. Each bit consists of three rotating inserts. The inserts (cones) have machined races cut into their interior surfaces. Likewise the corresponding shaft of the bit has three equally machined journal surfaces onto which these inserts are mounted. The rollers are placed, without retaining cages, between the journal and cone. In effect the manufacturer of the rock bit uses existing metal surfaces to act as the inner and outer races of the bearing. Since the rollers are imported loose, and since it is impossible to extract a separately distinguishable bearing (inner and outer race, rollers and cage), we would not view these rollers as parts of bearings.

The applicable subheading for the cylindrical rollers will be 8207.12.3090, Harmonized Tariff Schedule of the United States (HTS), which provides for interchangeable tools for handtools, whether or not power- operated, or for machine-tools: rock drilling or earth boring tools and parts thereof: with working parts of other material, and parts thereof: with cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium...other. The rate of duty will be 7.2 percent ad valorem.

It is the opinion of this office that the instant merchandise 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. The scope of this investigation covers ball and roller bearings and parts thereof. These rollers do not constitute parts of "bearings". 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.

Sincerely,

Jean F. Maguire
Area Director

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