The tariff classification of an unground thrust ringassembly from Great Britain

NY 862986 May 31, 1991 CLA-2-84:S:N:N1:102 862986 CATEGORY: Classification TARIFF NO.: 8482.10.5004 Mr. Thomas J. O'Donnell Sonnenberg, Anderson, O'Donnell & Rodriguez 200 West Adams Street, Suite 2625 Chicago, Illinois 60606 RE: The tariff classification of an unground thrust ring assembly from Great Britain Dear Mr. O'Donnell: In your letter dated April 30, 1991, on behalf of your client, Drilex Systems Inc., you requested a tariff classification ruling. The item in question is known as a thrust ring assembly. It consists of a series of stacked inner and outer contact rings with rows of steel balls placed between each set of rings. These thrust ring assemblies surround the drilling output shaft found in Drilex's downhole positive displacement motors. While the function of this thrust stack, which can contain 19 or more ring sets, is to reduce rotational friction while providing both upwards and downwards thrust support, it does so by utilizing friction. The metal used in the rings is not hardened to the same degree as is common in other bearings, and a desired result of the motor's rotation is to wear down a channel in each of the races. This wear, in conjunction with the fact that the balls are not held in cages (retainers) gives the stack the ability to laterally displace itself by up to two centimeters. This deflection ability allows the thrust assemble to flex in order to follow the necessary bending movement of the motor/drill through non-uniform surfaces. While your letter presents a number of arguments expressing your belief that this thrust ring assembly should not be subject to the current antidumping margins applicable to ball bearings, one of them is of utmost significance. The manufacturer provided detail information on the tolerance levels utilized in the production of both the balls and the rings. In the case of the balls, the maximum and minimum diameters differ by .15mm from the nominal diameter. The ring tolerance has a .25mm deviation in diameter. As such, based on the Explanatory Notes to the Harmonized Tariff Schedules, we would consider the thrust rings to be unground bearings. The applicable subheading for the thrust ring assemblies will be 8482.10.5004, Harmonized Tariff Schedule of the United States (HTS), which provides for unground ball bearings. The rate of duty will be 11 percent ad valorem. It is the opinion of this office that the thrust ring assemblies and their 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. The scope of the original dumping petition concerned itself with "precision" ball bearings and did not cover ungound bearings. Should you desire a binding ruling 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