CLA-2-84:S:N:N3:102 884561
Mr. Edward B. Ackerman
Siegel, Mandell & Davidson
One Astor Plaza
1515 Broadway
New York, N.Y. 10036
RE: The tariff classification of end plate assemblies for air
impact wrench from Japan
Dear Mr. Ackerman:
In your letter dated April 1, 1993, on behalf of your client,
Ingersoll Rand Company, you requested a tariff classification
ruling.
The items at hand are described as end plate assemblies and
are parts incorporated into a pneumatic impact wrench. The
assemblies consist of two steel
flanges, ground to a smooth surface and drilled (ported) with air
channels. In the center of each plate is a machined cavity in
which a single row, radial ball bearing is mounted. Inside the
impact wrench, the end plates are mounted on either side of the
pneumatic rotor and serve several functions. The bearings support
the spinning rotor and reduce friction. The plates themselves
serve to create an air-tight internal chamber for the rotor, while
the drilled ports are designed to direct the flow of air into the
cylinder in such a way as to strike the vanes and cause rotation.
We do not view the plates to function merely as flange mountings
for the bearings. Rather their configuration is such that they are
essential to the operation of the impact wrench. As such we would
consider them to be components "containing" bearings.
The applicable subheading for the end plate assemblies will be
8467.92.0090, Harmonized Tariff Schedule of the United States
(HTS), which provides for parts of tools for working in the hand;
pneumatic or with self-contained non-electric motors, and parts
thereof. The rate of duty will be 2.5 percent ad valorem.
It is the opinion of this office that the end plate assemblies
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. Should you
desire a binding scope decisions 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