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NY L87719

October 19, 2005

CLA-2-84:RR:NC:1:102 L87719


TARIFF NO.: 8482.99.0500

Mr. Vern Jarosak
Kinsho International Corporation
44 Wall Street
New York, New York 10048

RE: The tariff classification of machined rings for ball bearings from China

Dear Mr. Jarosak:

In your letter dated September 16, 2005 you requested a tariff classification ruling on behalf of Kinsho International Corporation.

The items in question are described as machined inner and outer rings for ball bearings. You indicate that the inner and outer rings are machined from tower forgings, which consist of an inner and outer ring in a single forging, and will be further processed after importation and used in the production of ball bearings. Further processing, prior to assembly of the rings with other components to form a complete ball bearing, will include heat treatment and grinding to final dimension.

The classification of the machined rings under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1 provides that classification shall be determined according to the terms of the tariff headings and any relative section or chapter notes. Heading 8482, HTSUS, provides for ball and roller bearings, and parts thereof. GRI 2(a) extends the scope of heading 8482 to include unfinished parts, provided the unfinished parts have the essential character of the finished parts.

The description of the machine rings you provided leads us to conclude that the unfinished rings are net shape blanks, which closely approximate the outline of the finished article they will form. Although the rings may not be to final tolerance and may lack the highly polished surfaces of finished races, upon importation they will possess the unique geometry that makes them readily recognizable as inner and outer rings for ball bearings. Further, the unfinished rings have no other practical use other than for completion into finished rings for ball bearings. We find that the subject rings are unfinished articles that have the essential character of the finished rings and races provided for in HTSUS heading 8482.

The applicable subheading for the unfinished rings will be 8482.99.0500, HTSUS, which provides for inner or outer rings or races for ball bearings. The rate of duty will be 9.9 percent ad valorem.

You have asked whether this product is subject to antidumping duties or countervailing duties. A list of AD/CVD proceedings at the Department of Commerce (DOC) and their product coverage can be obtained from the DOC website at: http://ia.ita.doc.gov, or you may write to them at the U.S. Department of Commerce, International Trade Administration, Office of Antidumping Compliance, 14th Street and Constitution Avenue, N.W. Washington, DC 20230. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection.

     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 646-733-3009.


Robert B. Swierupski

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