CLA-2-84:S:N:N1:102 867990
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 specific applications, as parts of
photographic developing equipment. As such you contend that they
should take the tariff classification for parts of such
equipment. The items involved are as follows:
1) part number CM10 (sample # 3), a plastic, single row
radial ball bearing. The part is used to support a roller
which feeds film into photographic developers.
2) part number CM6DHPP (sample # 6), a plastic, single row
radial ball bearing with an outer ring which has been molded
into a square shaped mounting. The inner ring has a D-
shaped bore designed to accept a "D" shaft in the paper feed
mechanism.
3) part number CM8PF70, PAKO CINE (samples # 7 & 8),
plastic, integral shaft ball bearings which contain a single
row of balls that ride on a hollow shaft. The shafts of
both samples are designed in such a way that they mate
together, forming a double row, integral shaft bearing.
The part is designed for use in rollers for a 70 mm reel
used in the processing of 70 mm film.
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, 2 and 3 above are clearly ball bearings and are
to be classified accordingly.
The applicable subheading for parts #CM10 and CM6DHPP will
be 8482.10.5044, Harmonized Tariff Schedule of the United States
(HTS), which provides for single row radial ball bearings, having
an outside diameter of 9 mm and over but not over 30 mm. The
rate of duty will be 11 percent ad valorem. Parts number
CM8PF70, PAKO CINE will be classifiable under 8482.10.1040, HTS,
which provides for ball bearings with integral shafts, having an
outside diameter not over 30 mm. The duty rate will be 4.2
percent ad valorem.
It is the opinion of this office that the above parts 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