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NY A86701




October 8, 1996

CLA-2-84:RR:NC:1:102 A86701

CATEGORY: CLASSIFICATION

TARIFF NO.: 8482.99.6530; 8482.99.6560; 8483.60.4000

Mr. Rick A. Catalani
Tower Group International
821 2nd Avenue, #1400
Seattle, WA 98104-1476

RE: The tariff classification of a cooling fan clutch and a thrust bearing race from Japan.

Dear Mr. Catalani:

In your letter dated August 15, 1996 you requested, on behalf of your client Isuzu Motors America, Inc., a tariff classification ruling.

The first item in question is a cooling fan clutch imported as a service replacement part. The clutch is a part of a cooling fan system utilized in various internal combustion engine vehicles. A diagram depicting the clutch as a component of the cooling fan assembly was submitted.

The applicable subheading for the cooling fan clutch will be 8483.60.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for clutches and shaft couplings. The rate of duty will be 4.5 percent ad valorem.

The second item in question is a thrust bearing race, also imported as a replacement service part. A sample, together with diagrams depicting the bearing race as it is used in an automatic transmission assembly for a motor vehicle, were submitted. You state in your request that the race is not a part of a ball or roller bearing, but rather used in conjunction with a complete thrust bearing.

The submitted diagrams reveal that the race is used in conjunction with a roller and cage assembly, consisting of a set of cylindrical rollers assembled with its cage. However, in addition to a roller and cage assembly, a complete cylindrical roller thrust bearing includes two washers, generally a shaft washer and a housing washer, which serve as raceways for the caged rollers. The thrust bearing race in question serves as a raceway and is an essential load supporting component of the complete bearing assembly.

The classification of the bearing race is controlled by the dimensions of the rollers contained in the roller and cage assembly. Cylindrical rollers of a uniform diameter not exceeding 5 mm and having a length which is at least three times the diameter are considered for the purposes of classification as needle rollers. Dimensional data for the caged rollers was not submitted.

The applicable subheading for the trust bearing race, if used with needle rollers, will be 8482.99.6530, Harmonized Tariff Schedule of the United States (HTS), which provides for parts for needle roller bearings. The rate of duty will be 6.2 percent ad valorem.

If the race is used with cylindrical rollers other than needle rollers, the applicable subheading will be 8482.99.6560, HTS, which provides for parts for other cylindrical roller bearings. The duty rate will remain unchanged at 6.2 percent ad valorem.

It is the opinion of this office that the thrust bearing race would be subject to anti-dumping (ADA) and countervailing duty (CVD) margins under the current Department of Commerce ADA and CVD findings on bearings, as published on May 15, 1989. Please contact your local port for the specific case numbers and percentages for each case. If you desire a binding ruling on the applicability of either anti-dumping or countervailing duty to your product, please write directly to the Office of Compliance, Department of Commerce, 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 212-466-5493.

Sincerely,

Roger J. Silvestri

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