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NY J82938

April 21, 2003

CLA-2-69:RR:NC:2:227 J82938


TARIFF NO.: 6903.20.00

Mr. Michael A. Capuzzi
6314 North Wyndwood Drive
Crystal Lake, IL 60014

RE: The tariff classification of ceramic roller blanks

Dear Mr. Capuzzi:

In your letter dated March 28, 2003, on behalf of Bolt Technical Ceramics, you requested a tariff classification ruling of ceramic roller blanks imported into the United States for further processing.

You identify the imported ceramic roller blanks as styles Sillimantin 60 and Sillimantin 65. Each is approximately 100 inches in length with an outside diameter of 1½ inches. Upon entry into the U.S., the ceramic roller blanks, which are indicated to meet the definition of the term “refractory”, are classified under HTS 6903.20.00.

In the United States the ceramic roller blanks will undergo the following process:

Cutting the rollers to the proper length
Grinding the outside diameter of the ends to the required size Adding slots and notches to accommodate specific kiln fittings Adding six inches of ceramic fiber to each end to increase heat resistance

After this processing is completed, the ceramic rollers will be shipped to Mexico as replacement parts for gas-fired kilns to move the product to be fired through the kiln. You maintain that the finished ceramic rollers, as parts of gas-fired kilns, are classifiable under HTS 8417.90 the provision for parts of industrial or laboratory furnaces and ovens.

Subheading 8417.90, HTS, does provide for parts of industrial or laboratory furnaces or ovens. However, ceramic rollers are not classifiable in chapter 84 by virtue of Legal Note 1(b). Legal Note 1(b) states “This chapter does not cover: Machinery or appliances (for example, pumps) of ceramic material and ceramic parts of machinery or appliances of any material (chapter 69).” Therefore, subheading 8417.90, HTS, does not apply.

The applicable tariff provision for the ceramic rollers will be 6903.20.00, Harmonized Tariff Schedule of the United States (HTS), which provides for other refractory ceramic goods. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

We suggest that you request a NAFTA eligibility ruling from Mexico.

If you have any questions regarding the ruling, contact National Import Specialist George Kalkines at 646-733-3028.


Robert B. Swierupski

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