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NY N026578

May 9, 2008



TARIFF NO.: 7326.90.8587

Ms. Tracy Somora
Mid-America Overseas, Inc.
201 South Prospect Avenue
Itasca, IL 60143

RE: The tariff classification of lifting points and load rings from Germany

Dear Ms. Somora:

In your letter dated April 17, 2008, on behalf of Rud Chain, you requested a tariff classification ruling on lifting points and load rings. Samples of the merchandise were submitted for our review.

     The merchandise is identified as the PowerPoint PP and Load Ring WBG-V/WBG. You indicate that the merchandise is made of steel and used to attach chains to other items for lifting and loading. The literature describes the PowerPoint PP as lifting and lashing points that have universal connections for lifting apparatus (hook and ring assemblies, basket chains, round slings, loops, etc.). Each PowerPoint PP features a double ball bearing for smooth lifting, tilting and turning operations. The literature describes the Load Ring WBG-V/WBG as heavy duty lifting rings with ball bearing swivels that are suitable for turning and tilting loads.

You propose classification of the PowerPoint PP and Load Ring WBG-V/WBG under subheading 7315.90, Harmonized Tariff Schedule of the United States (HTSUS), which provides for chain and parts thereof, of iron or steel, other parts. However, these items are not used exclusively with chain and are not part of the chain. They are not attached to the end of a chain to make a connection. Rather, they are designed to be bolted to the load lifting apparatus. As such it is not classifiable as part of a chain in subheading 7315.90.

You ask whether the PowerPoint PP and Loading Ring WBG-V/WBG should be considered bearings as the ball bearings in these items allow for the swivel movement in the items. The PowerPoint PP and Loading Ring WBG-V/WBG are items incorporating bearings, not articles of heading 8424, which provides for ball or roller bearings, and parts thereof.

Your samples will be returned as requested.

The applicable subheading for the PowerPoint PP and Load Ring WBG-V/WBG will be 7326.90.8587, HTSUS, which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Ann Taub at 646-733-3018.


Robert B. Swierupski

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