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HQ 965245

APRIL 24, 2002

CLA-2 RR:CR:GC 965245 JAS


TARIFF NO.: 8482.10.50

Port Director of Customs
P.O. Box 55580
Portland, OR 97238-5580

RE: Protest 2904-00-100091; Turntable Bearing

Dear Port Director:

This is our decision on Protest 2904-00-100091, filed on behalf of Sturdy-Weld Equipment & Design, Inc., against your classification, under the Harmonized Tariff Schedule of the United States (HTSUS), of turntable bearings. The entry was liquidated on June 2, 2000, and this protest timely filed on August 22, 2000. Drawings and other descriptive literature were submitted. Counsel for the protestant made an additional submission, dated April 19, 2002.


The merchandise is referred to variously as parts for non mechanically-propelled trailers, as turntable bearings or as turntable slewing rings. These articles are advertised for use with trailers with turntable steering. Counsel describes the article as consisting of an inner and outer unit or ring which houses polished steel balls to form a bearing assembly which attaches over the fifth wheel of a truck tractor. A submitted picture essentially confirms this description but shows the article attaching a non mechanically-propelled trailer to the rear underside of a truck tractor.

The merchandise was entered under a provision in heading 8716, HTSUS, as parts of trailers, not mechanically propelled. The merchandise was rate-advanced under a provision for other ball or roller bearings, in heading 8482, HTSUS, and a Notice of Action, Customs Form 29, issued to the protestant assessing additional antidumping duties. The entry liquidated in due course.

The HTSUS provisions under consideration are as follows:

Ball or roller bearings, and parts thereof:


8716 Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof:

8716.90 Parts:

8716.90.50 Other


Whether the turntable bearing is a good of heading 8482; whether it is subject to an Anti-Dumping Duty Order.


Under General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), goods are to be classified 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.

On protest, counsel’s argument is that the article at issue is substantially similar in design and function to a turntable slewing ring which mounts the trailer to the underside of a truck tractor and permits the trailer to turn freely while being pulled. NY DD873025, dated May 4, 1992, classified ball bearing turntables, also known as slewing rings, in subheading 8482.10.5028, HTSUS, as angular contact ball bearings. The ruling also noted that slewing rings were not covered by the applicable dumping case on this merchandise.

Initially, the merchandise at issue, whether known as turntables, turntable bearings or slewing rings, is to be distinguished from “geared” slewing rings the subject of Rollix Bearing, Inc., v. United States, 15 C.I.T. (1991). In that case, decided under the HTSUS predecessor tariff code, the Tariff Schedules of the United States (TSUS), slewing rings with geared teeth cut either into the outside of the outer bearing ring or the inside of the inner bearing ring, the teeth functioning to transmit torque and power, were
found to be classifiable as parts of fixed ratio speed changers. The articles at issue here do not have geared teeth. See HQ 960553, dated October 17, 1997, which classified “gearless” slewing rings in subheading 8482.10.50, HTSUS.

The parties agree that the classification expressed in NY DD873025 at the 8-digit tariff rate subheading level applies to the merchandise in this protest. At liquidation, the bearing was considered a thrust bearing described in statistical suffix “08.” In fact, the subject bearing is an angular contact bearing described in statistical suffix “28.” The statement in NY DD 873025 on the exclusion of “slewing rings” from an Anti-Dumping Duty Order on substantially similar merchandise is advisory only, and is not binding on the Government. As that ruling instructed, “binding” rulings on the scope of dumping orders issue from the Office of Compliance, Department of Commerce.


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

The protest should be DENIED. In accordance with Section 3A(11)(b) of Customs Directive 099 3550-065, dated August 4, 1993, Subject: Revised Protest Directive, you are to mail this decision, together with the Customs Form 19, to the protestant no later than 60 days from the date of this letter. Any reliquidation of the entry or entries in accordance with the decision must be accomplished prior to mailing the decision. Sixty days from the date of the decision the Office of Regulations and Rulings will make the decision available to Customs personnel, and to the public on the Customs Home Page on the World Wide Web at www.customs.gov, by means of the Freedom of Information Act, and other methods of public distribution.


John Durant, Director
Commercial Rulings Division

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