NY 861287
APR 04 1991
CLA-2-84:S:N:N1:102 861287
Ms. Shari Smith
Tente Casters, Inc.
P.O. Box 18638
1211 Cox Avenue
Erlanger, Kentucky 41018
RE: The tariff classification of needle roller bearings,
antifriction steel balls, and inner rings for ball bearings from
Germany
Dear Ms. Smith:
In your letter dated March 6, 1991 you requested a tariff
classification ruling.
Your inquiry deals with specific imported components used in
the production of casters and wheels. All of these items are
some form of antifriction bearing or parts of such bearings.
With your letter you provided us with samples and labelled them
"I" to "M". Sample "I" is called a ball scale (DAK 050). This
is the inner race that is pressed into a wheel body and functions
as the bearing surface upon which antifriction steel balls will
rotate. Samples "J". "K", and "L" are needle roller bearing
inserts. These units consist of a plastic cage, or retainer,
fitted with several needle rollers. They are later inserted into
the body of a wheel and function as friction reducing elements.
Sample "M" consists of two sizes of steel balls, 7/32 and 1/4
inch in diameter. These balls are to be incorporated into the
swivel portion of a steel caster.
The applicable subheading for the needle roller bearings,
samples "J", "K" & "L", will be 8482.40.0000, Harmonized Tariff
Schedule of the United States (HTS), which provides for needle
roller bearings. The rate of duty will be 6.5 percent ad
valorem. The ball scale, sample "I", is classifiable under the
heading covering parts of ball bearings, inner and outer races,
HTS item 8482.99.1010. The duty rate will be 11 percent ad
valorem. The steel antifriction balls, sample "M", will be
classified under 8482.91.0010, which provision covers parts of
ball bearings, steel alloy balls. The duty rate is 4.9 percent
ad valorem.
It is the opinion of this office that the three models of
needle roller bearings would not be subject to antidumping duties
under the current Department of Commerce antifriction bearing
dumping investigation, as published in the Federal Register on
May 15, 1989. The grounds for this determination are that we
would consider this to be covered under the exclusion for needle
roller bearings. On the other hand, the ball scale and the steel
balls would be covered by the dumping order under the category of
"parts of ball bearings". Please contact your local port for the
applicable case number and current dumping margins. Should you
desire a binding ruling on the applicability of this ADA case to
your merchandise, please write directly to the Department of
Commerce, Office of Compliance, Washington, D.C.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport