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NY C81446




November 25, 1997

CLA-2-39:RR:NC:SP:221 C81446

CATEGORY: CLASSIFICATION

TARIFF NO.: 4016.93.5050; 8482.99.3500

Mr. Donald S. Simpson
Barthco Trade Consultants, Inc.
7575 Holstein Avenue
Philadelphia, PA 19153

RE: The tariff classification of metal rings and rubber and metal seals from Italy.

Dear Mr. Simpson:

In your letter dated October 22, 1997, on behalf of SKF USA, you requested a tariff classification ruling.

Two sample seals were provided with your letter. The seals consist of a metal ring covered with nitrile-butadiene rubber (NBR). The seals will be used in tapered roller bearings. Metal rings will also be imported. After importation, the rings will be phosphated and covered with rubber for use in ball bearings for HUB Units.

The applicable subheading for the seals consisting of metal rings covered with rubber will be 4016.93.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of vulcanized rubber other than hard rubber...gaskets, washers and other seals, other. The rate of duty will be 2.9 percent ad valorem.

The applicable subheading for the metal rings will be 8482.99.3500, HTS, which provides for parts: other: parts of ball bearings. The rate of duty will be 10.3 percent ad valorem.

It is the opinion of this office that the metal rings and the metal and rubber seals would both be subject to anti-dumping margins under current Department of Commerce orders related to antifriction bearings. 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 products, 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 Joan Mazzola at 212-466-5580.

Sincerely,

Robert B. Swierupski
Director,

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