CLA-2-84:OT:RR:NC:1:102
Sharon Pearce
Jack Lewin Associates INC
TCM International
P.O. Box 66381
Chicago IL, 60666
RE: The tariff classification of a Trolley Bearing from China.
Dear Ms. Pearce:
In your letter dated February 3, 2015, on behalf of VNC Bearing Inc., you requested a tariff classification ruling. A sample of the Trolley Bearing was submitted with your request and will be returned to you.
The item under consideration is described as the Model 527, Trolley Bearing. The item is comprised of a convex shaped steel outer race, which also constitutes as the outside surface and the rolling surface of the Trolley Bearing. The item also includes a two-piece split inner race pressed together and two rows of 13 steel balls, which are contained by the inner and outer race. The two-piece split inner race is designed to hold or lock the outer race and steel balls once pressed together. The outside diameter of the Trolley Bearing measures approximately 30 millimeters and the inside diameter measures approximately 6.6 millimeters. The information provided indicates that the Trolley Bearing is part of a Trolley assembly used in the dry cleaning industry and its specific application is to support clothes on hangers.
In your letter, you suggest classification of the Trolley Bearing in subheading 8482.20.0000 Harmonized Tariff Schedule of the United States (HTSUS), which provides for tapered roller bearings, including cone and tapered roller assemblies. However, tapered roller bearings include inner and outer ring raceways that are segments of cones with rollers that are also made with a taper so that the conical surfaces of the raceways and the roller axes if projected, would all meet at a common point on the main axis of the bearing. From all the information submitted, the Trolley Bearing at issue clearly does not possess any of those characteristics. Further, for tariff purposes, a bearing housing consists of a frame or block designed to house an otherwise complete bearing. Because the Trolley Bearing housing in this case is actually the outer race and completes the Trolley Bearing, it does not house the bearing. Therefore, the Trolley Bearing, which incorporates steel raceways and a double row of steel balls as rolling elements, is essentially a double row radial ball bearing used to minimize friction in a trolley assembly.
Merchandise is classifiable under the HTSUS in accordance with the General Rules of Interpretation (GRIs). GRI 1 states that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes. Under the authority of GRI 1, we find the Trolley Bearing is specifically provided for in heading 8482, HTSUS. As such, the applicable subheading for the Model 527, Trolley Bearing, will be 8482.10.5060, HTSUS, which provides for double row radial ball bearings. The rate of duty will be 9 percent ad valorem. 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 National Import Specialist Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division