The tariff classification of ring forgings from China

N220315 July 3, 2012 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8483.90.5000 Mr. Steven R. Keller Cascade Corporation 2201 NE 201st Avenue Fairview, OR 97024 RE: The tariff classification of ring forgings from China Dear Mr. Keller: In your letter dated June 5, 2012 you requested a tariff classification ruling. The articles you plan to import are described as ring forgings of “slewing rings” for use in material handling products for lift trucks. Descriptive literature and photographs were included with your submission. You state that the ring forgings are produced in China from either alloy steel (AISI 4140) or carbon hot rolled steel (AISI C-1045 HR). These donut shaped, partially machined forgings are, at the time of importation, unfinished components of slewing rings and will become either the inner or outer race/ring of a slewing ring. After importation, a number of machining operations are performed on the unfinished rings/races which include the drilling of mounting holes, gear teeth cutting and hardening and grinding and induction hardening of the ball path. Once the machining process is completed, the slewing ring is assembled. Ball bearings will sit within the machined parts of both the inner and outer race holding the two together and allowing rotation. The issue at hand is whether the forgings as imported from China are classified as parts of bearings provided for in heading 8482, Harmonized Tariff Schedule of the United States (HTSUS) or are they classified as parts of gears and gearing provided for in heading 8483, HTSUS. A similar matter was addressed in Headquarters Ruling HQ 083066. In that ruling, it was determined that the principal function of the slewing ring was the gear function and that the unfinished/partially machined forgings which will have gear teeth machined into them after importation were classifiable as parts of gears and gearing in heading 8483, HTSUS. Therefore, in accordance with ruling HQ 083066, the subject forgings should be classified as parts of gears and gearing. The applicable subheading for the ring forgings will be 8483.90.5000, HTSUS, which provides for parts of gears, gearing, gear boxes and other speed changers. The rate of duty will be 2.5 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 Kenneth T. Brock at (646) 733-3009. Sincerely, Thomas J. Russo Director National Commodity Specialist Division