CLA-2-84:OT:RR:NC:N1:102
Ms. Marianna Barbulescu
Dext Services, Inc.
17830 Harbour Bridge Point Drive
Cypress, TX 77429
RE: The tariff classification of linear cylindrical roller bearings assembled abroad from U.S. components.
Dear Ms. Barbulescu:
In your letter dated April 2, 2013 you requested a tariff classification ruling. Representative samples were included with your submission and will be retained by this office.
The items under consideration are linear bearing assemblies for use in gripper devices (robotic hands). The bearing assemblies are comprised of steel cylindrical rollers held in place by a plastic cage.
You indicate that the rollers and cages along with Molycote and Krytox grease, all products of the United States, will be shipped to your company in Singapore for assembly and lubrication. The assembled bearing will then be exported to the United States for sale to your customers.
The applicable subheading for the linear bearing assemblies will be 8482.50.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for ball or roller bearings, and parts thereof, other cylindrical rollers. The rate of duty will be 5.8 percent ad valorem.
A partial duty exemption is applicable for certain components of U.S. origin assembled in another country. Subheading 9802.00.80, HTSUS, provides for articles assembled abroad in whole or in part of fabricated components, the product of the United States, which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape, or otherwise, and (c) have not been advanced in value or improved in condition except by being assembled or except by operations incidental to the assembly process, such as cleaning, lubricating and painting.
All three requirements of this subheading must be satisfied before a component may receive a duty allowance. The duty will be determined upon the value of the imported article, less the cost or value of the fabricated components of the United States.
The cylindrical rollers and plastic cages meet the requirements of subheading 9802.00.80, HTSUS. These components are in condition ready for assembly prior to being exported from the United States and do not lose their physical identity after being assembled. In addition, they are not advanced in value except by operations incidental to the assembly process. As such, a partial duty exemption will apply for the rollers and cages.
The lubricating material, however, does not meet the requirements of subheading 9802.00.80, HTSUS. The Molycote and Krytox grease are not fabricated components and will lose their identity in the assembly process. Therefore, a partial duty exemption will not apply for the grease.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.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 the National Import Specialist at (646) 733-3009.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division