CLA-2-84:S:N:N1:102 867989
Mr. Robert S. Smith
McGuire, Woods, Battle & Boothe
The Army and Navy Club Building
1627 Eye Street N.W.
Washington, D.C. 20006
RE: The tariff classification of assorted plastic components
from England
Dear Mr. Smith:
In your letter dated October 2, 1991, on behalf of your U.S.
client, IABC, you requested a tariff classification ruling.
In your original inquiry you stated that the sampled parts
submitted were all for use in swimming pool vacuum cleaners
exclusively and that, as such they should take the tariff
classification for parts of vacuum cleaners. The items involved
are as follows:
1) part number CMH 8 MDW (sample # 2), a plastic, double row
radial ball bearing with hexagonal shaped opening through
the inner ring, used as a cam follower on the propulsion
system of the pool cleaner.
2) part number CM 16002 (sample # 5), a plastic, single row
radial ball bearing with three slots cut in the inner ring,
used to support the rotating turbine.
3) part number D1077 (sample # 22), a plastic hose swivel
connector, threaded at one end, with a push on hose
connection at the other end. It is used to join the pool
cleaner to the water feed hose.
While it may be that the above parts are specifically
designed for use only as components of a larger system, that fact
does not override the directives in the General Rules of
Interpretation (GRI's) to the Harmonized Tariff Schedules (HTS)
of the United States. The GRI's stipulate that a "part" of an
article, which itself is specifically provided for in one of the
subheadings of the HTS, must be classified within that "eo
nomine" provision before being considered a "part" of the overall
device. Items 1 and 2 above are clearly ball bearings and are to
be classified accordingly.
The applicable subheading for part #CMH 8 MDW will be
8482.10.5060, Harmonized Tariff Schedule of the United States
(HTS), which provides for double row radial ball bearings. The
rate of duty will be 11 percent ad valorem. Part number CM 16002
is classifiable under 8482.10.5044, HTS, which provides for
single row radial ball bearings, having an outside diameter of 9
mm and over but not over 30 mm. The duty rate will be 11
percent ad valorem.
The tariff classification of the plastic hose connector,
part number D1077, will be 8421.99.0040, HTS, which provides for
other parts of filtering or purifying machinery and apparatus.
The duty rate will be 3.9 percent ad valorem.
It is the opinion of this office that parts # CMH 8 MDW and
CM 16002 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. Thermoplastic bearings were specifically excluded from the
scope of this investigation. Should you desire a scope
determination 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