CLA 2 CO:R:C:G 083066 APS 827137
Mr. C. R. Stewart III
Kaydon Corporation
2860 McCracken
P.O. Box 688
Muskegon, Michigan 49443
RE: Request for tariff classification ruling for forgings used on slewing rings (also called turntable bearings) under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).
Dear Mr. Stewart:
Your letter of December 10, 1987, addressed to Customs in New York requesting the tariff classification of the subject merchandise has been referred to Headquarters for reply.
FACTS:
You state the forgings will be produced in Mexico from carbon steel AISI 1045 1050, or modified steel 1552, and not the usual bearing grades of steel, such as 52100, 8620, or M50.
The process begins with steel cut from an ingot or billet, heated and forged in an open die forging press to form a pancake. It is then punched to form a hole through the center
to produce a donut shape. The donut shape is then rolled on a ring roller which expands the ring to roughly its finished outside and inside diameter and height. The forgings are then heat treated. The forging process leaves the rings warped, i.e., out of round (egg shaped) and out of flat across the faces. The forgings are then rough machined to correct out of roundness and flatness and to remove scale, decarb and surface defects. They are not subjected to any surface treatment.
The forgings are then finish machined on all flat surfaces to final size on the outside and inside diameters and the faces (height). The seal grooves and ball path are added. The load
plug hole is drilled. Its location depends on whether the hole is placed on the outer or inner race.
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These partially machined forgings will become either the inner or outer race/ring of a slewing ring. They are, at time of importation, unfinished components of slewing rings. They
are incomplete and by themselves cannot function as slewing rings.
Operations performed on the unfinished parts of slewing rings after importation are induction hardening of the ball path, drilling of mounting holes, gear teeth cutting, and grinding of the ball path. Assembly follows and each slewing ring includes one outer race, one inner race, balls, separators, seals, grease, load plug and pin.
These slewing rings have use on large mechanical equipment such as cranes, excavators, naval gun mounts, rocket launchers, large scale metal working machines and other rotating equipment which carry large eccentric loads.
We understand that there is a bearing much akin to the slewing ring but without the gear teeth which we shall refer to as a turntable bearing.
A turntable bearing consists of two rings or races laid one over the other with a row of ball or roller bearings sandwiched in between. In this condition the article is essentially a large thrust bearing and is used to reduce rotational (pivotal) friction between two surfaces. An example of this would be where a truck is towing a trailer and the turntable is bolted to the back beam supports of the truck to provide a frictionless pivot between the truck and the trailer
thus functioning somewhat in the manner of the "fifth wheel" on a tractor trailer rig. This application of the turntable bearing meets the basic working definition of a bearing.
ISSUE:
Are the forgings as imported from Mexico parts of bearings provided for in heading 8482 HTSUSA or are they parts of gears and gearing provided for in heading 8483.
LAW AND ANALYSIS:
We consider a slewing ring to be a machine adapted for the purpose of two or more complementary or alternative functions. As such, it will be classified as if being that machine which performs the principal function. Section XVI Notes 3 and 5, HTSUSA. Thus, we must determine what the principal function of a slewing ring is.
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It is our determination that the principal function of a slewing ring is the gear function. We make this determination because turning (slewing) is the reason the machine is used.
The machine could perform without the ball bearing function but not without the gear function. The balls used in the slewing ring provide a secondary function of reducing friction and requiring less torque. Rotation could be accomplished without the balls but at a much higher torque requirement. However, without the gear function there could be no rotation at all.
HOLDING:
The forgings which will have gear teeth machined into them after exportation to the United States are classifiable as parts of gears and gearing under heading 8483.90.5000, HTSUSA, with duty at the rate of 2.5 percent ad valorem.
Sincerely,
John Durant, Director
Commercial Rulings Division