CLA-2-87:OT:RR:NC:N1:101
Donald S. Simpson, Senior Vice President
BARTHCO
5101 South Broad Street
Philadelphia, PA 19112-1404
RE: The tariff classification of suspension parts from an unspecified country
Dear Mr. Simpson,
In your letter dated July 27, 2010, you requested a tariff classification ruling on behalf of your client, SKF USA, Inc. of Norristown, Pennsylvania.
The items under consideration have been identified as Thrust Bearings (Part #’s BDA1113A, BDA1113B, BDA1113D, BXBDA1113A, BYBDA1113B and BZBDA1113B). A sample was provided and will be returned as per your instructions.
The Thrust Bearings are used in the mounting and operation of a McPherson Strut Assembly. Typically, the McPherson Strut is used in the steerable, front suspension of a motor vehicle, but may also be used in the rear suspension. The parts referenced above are located in the strut assembly between the coil spring and the structure of the vehicle. Their function is to allow free rotation of the top of the spring that normally occurs when the coil spring is compressed and allows rotation of the complete strut assembly when used with suspensions for steered wheels. You provided a sample of a Thrust Bearing (Part # BDA1113B) which measures approximately 4 ¾ inches in diameter and 2 inches in height.
You state that each article is an assembly of two (2) steel thrust washers, steel balls and a cage contained in a plastic enclosure. The washers, balls, and cage form a thrust bearing with the washers serving as raceways and the balls as roller elements. The enclosure is formed by two pieces of plastic which snap together to form the housing for the bearing. The housing serves to align the axis of the bearing with the axis of the strut assembly and facilitates mounting the bearing between the fixed vehicle structure and the rotating coil spring.
The applicable classification subheading for the Thrust Bearings (Part #’s BDA1113A, BDA1113B, BDA1113D, BXBDA1113A, BYBDA1113B and BZBDA1113B) will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts … of … motor vehicles … : Suspension systems and parts thereof … : Parts: Other: Other: Other.” The general rate of duty will be 2.5%.
Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at http://ww.usitc.gov /tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Richard Laman at 646-733-3017.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division