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NY C82045


June 22, 1998

CLA-2-84:RR:NC:1:102 C82045

CATEGORY: CLASSIFICATION

TARIFF NO.: 8482.10.5004

Mr. Dennis Wilks

Kilian Manufacturing

75 Torlake Cr.

Toronto, Ontario

Canada M8Z 1B7

RE: The tariff classification of unground ball bearings from Canada.

Dear Mr. Wilks:

In your letter you requested a tariff classification ruling on behalf of Kilian Manufacturing.

The items in question are described as "unground" bearings and identified by numbers SR-254-9001-66, SR-254-9001-67 and SR-

254-9001-55. Descriptive information, technical drawings and samples were submitted.

The subject bearings are radial bearings containing a single row of steel balls which serve as rolling elements. The inner and outer races of the bearing are machined on multi-spindle automatic screw machines from solid bar stock.

The bar stock is fed into the screw machine where a forming tool shapes and sizes the outer diameter of the races, while the inner diameter is drilled and reamed to size. Another forming tool then shapes the single ball track. Once shaped, the track is then burnished with a burnishing tool to produce the finished surface on which the rolling elements will roll. To complete the machining process, a cut-off blade separates the completed race from the bar stock.

The machined inner and outer races are then subjected to heat treatment and case hardened to specification and the outer diameter of the outer race is ground to tolerance, presumably to facilitate mounting. The races are then washed and ready for assembly with the rolling elements to form a completed bearing.

Ball and roller bearings are provided for in heading 8482 of the Harmonized Tariff Schedule of the United States (HTSUS). Subheading 8482.10.5004, HTSUS, provides for unground ball bearings. The question raised by your request is whether the grinding of the outer diameter of the outer race precludes treatment of the subject bearings as unground bearings for tariff purposes.

In our opinion the term "unground bearings" within the context of subheading 8482.10.5004, HTSUS, refers to ball bearings manufactured with unground raceways. This opinion comports with our understanding that the raceway is a critical load bearing surface within a rolling bearing and is the section of the race which significantly impacts the function of a ball or roller bearing. Clearly, the design of the raceway is a primary consideration in realizing the desired operating characteristics of a rolling bearing, and should merit equal consideration in determining the classification of a bearing for tariff purposes.

The raceways of the bearings considered here were designed to be burnished, rather than ground. Burnishing is a finishing process which serves to compress the surface of the raceway creating a smooth, lustrous finish, with a slight surface hardness. Unlike grinding, which involves the removal of surface material by abrasive action, burnishing is effected simply by applying a blunt tool under pressure to the surface of the raceway.

Accordingly, because the raceways are not ground, we find the subject bearings to be unground for tariff purposes.

The applicable subheading for the SR-254-9001-66, SR-254-

9001-67 and SR-254-9001-55 ball bearings will be 8482.10.5004, HTSUS, which provides for unground ball bearings. The general rate of duty will be 9.4 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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,


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