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NY 867988


November 12, 1991

CLA-2-84:S:N:N1:102 867988

CATEGORY: CLASSIFICATION

TARIFF NO.: 8482.10.5044

Mr. Robert S. Smith
McGuire, Woods, Battle & Boothe
The Army and Navy Club Building
1627 Eye Street N.W.
Washington, D.C. 20006

RE: The tariff classification of assorted plastic components from England

Dear Mr. Smith:

In your letter dated October 2, 1991, on behalf of your U.S. client, IABC, you requested a tariff classification ruling.

In your original inquiry you stated that the sampled parts submitted were all for use in swimming pool vacuum cleaners exclusively and that, as such they should take the tariff classification for parts of vacuum cleaners. The items involved are as follows:

1) part number AC3H22 (sample # 1), a plastic radial ball bearing with hexagonal shaped opening through the inner ring, used to align the shafts of mounting turbines to the pool cleaner.

2) part number AC10 LPV (sample # 4), a plastic radial ball bearing with extended inner ring, used, in pairs as a wheel support.

3) part number LP6 (sample # 14), a plastic radial ball bearing with a splined inner ring and an outer ring which has been extruded into the shape of a pillow block housing. This housing and outer ring are one. The item is used to support a splined drive shaft.

While it may be that the above parts are specifically designed for use only as components of a larger system, that fact does not override the directives in the General Rules of Interpretation (GRI's) to the Harmonized Tariff Schedules (HTS) of the United States, which stipulate that a "part" of an article, which itself is specifically provided for in one of the subheadings, must be classified within that "eo nomine" provision before being considered a "part" of the overall device. The applicable subheading for parts #AC3H22, AC10 LPV, and LP6 will be 8482.10.5044, Harmonized Tariff Schedule of the United States (HTS), which provides for single row radial ball bearings, other than maximum or full capacity type, having an outside diameter 9 mm and over but not over 30 mm. The rate of duty will be 11 percent ad valorem.

It is the opinion of this office that the instant merchandise 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. Thermoplastic bearings were specifically excluded from the scope of this investigation. Should you desire a scope determination 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

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