The tariff classification of machined rings for ball bearings from China and Japan

NY F89316 July 28, 2000 CLA-2-84:RR:NC:1:102 F89316 CATEGORY: Classification TARIFF NO.: 8482.99.0500 Mr. Vern Jarosak Kinsho International Corporation 44 Wall Street New, York, New York 10048 RE: The tariff classification of machined rings for ball bearings from China and Japan Dear Mr. Jarosak: In your letter dated June 28, 2000 you requested a tariff classification ruling on behalf of Kinsho International Corporation . The items in question are described as fully machined inner and outer rings for ball bearings. Descriptive information was submitted. You indicate that the inner and outer rings are machined from cut tubes or forged blanks and will be further processed after importation and used in the production of ball bearings. Further processing, prior to assembly of the rings with other components to form a complete ball bearing, will include heat treatment, presumably to impart surface hardness, and grinding to final dimension. The classification of the machined rings under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1 provides that classification shall be determined according to the terms of the tariff headings and any relative section or chapter notes. Heading 8482, HTSUS, provides for ball and roller bearings, and parts thereof. GRI 2(a) extends the scope of heading 8482 to include unfinished parts, provided the unfinished parts have the essential character of the finished parts. The description of the machine rings you provided leads us to conclude that the unfinished rings are net shape blanks, which closely approximate the outline of the finished article they will form. Although the rings may not be to final tolerance and may lack the highly polished surfaces of finished races, upon importation they will possess the unique geometry that makes them readily recognizable as inner and outer rings for ball bearings. Further, the unfinished rings have no other practical use other than for completion into finished rings for ball bearings. We find that the subject rings are unfinished articles that have the essential character of the finished rings and races provided for in HTSUS heading 8482. The applicable subheading for the unfinished rings will be 8482.99.0500, HTSUS, which provides for inner or outer rings or races for ball bearings. The rate of duty will be 9.9 percent ad valorem. It is the opinion of this office that the unfinished rings are not subject to antidumping duties. Parts of ball bearings that will be subject to heat treatment after importation to the United States are not within the scope of current orders of the Department of Commerce relating to antifriction ball bearings. Should you desire a binding ruling on the applicability of dumping orders 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 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 Kenneth T. Brock at 212-637-7026. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division