The tariff classification of end plate assemblies for airimpact wrench from Japan

NY 884561 APRIL 30, 1993 CLA-2-84:S:N:N3:102 884561 CATEGORY: Classification TARIFF NO.: 8467.92.0090 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