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NY F85886




April 26, 2000

CLA-2-87:RR:NC:MM:101 F85886

CATEGORY: CLASSIFICATION

TARIFF NO.: 8482.99.2560, 8708.93.7500

Mr. Ralph Garcia
Customs Specialist
Mitsubishi Motor Sales of America
6400 Katella Avenue
Cypress, California 90630-5208

RE: The tariff classification of Races for automatic transmissions from Japan

Dear Mr. Garcia:

In your letter dated April 10, 1999 you requested a tariff classification ruling.

You submitted samples as well as technical drawings for Races, imported by Mitsubishi Motor Sales as service parts for automatic transmissions.

Part # MR336788 Race, A/T One Way Clutch (Attachment I)

This part is a component of the one-way clutch of an automatic transmission. The one-way clutch is a mechanical device that allows free rotation of the outer race in one direction. When the outer race attempts to move in the opposite direction, the hub locks up and prevents movement. The race, A/T clutch, works with the center support by interlocking grooves preventing movement in the wrong direction. A bearing does not ride on this component.

Part # MD715387 Race, A/T Clutch (Attachment II)

This part is a component of the rear clutch assembly of an automatic transmission. The Race, A/T Clutch provides a flat surface to equalize pressure within the rear clutch assembly. A bearing does not ride on this component.

Part # MD704936 Race, A/T Brake (Attachment III)

This part is a component of the rear clutch assembly of an automatic transmission. The Race, A/T Brake provides a smooth, hard, non-moving surface for a cylindrical thrust bearing (#8) to ride on. The part works with the cylindrical thrust bearing to reduce friction between the rear clutch hub and the kickdown brake drum. The cylindrical bearing and the Race, A/T Brake are two distinct parts and are imported separately.

Part # MD735063 Race, A/T Power Train (Attachment IV)

This part is a component of the planetary carrier assembly of an automatic transmission. The Race, A/T Power Train provides a smooth, hard, non-moving surface for a cylindrical thrust bearing (#8) to ride on. The part works with the cylindrical thrust bearing to reduce friction between the forward sun gear and the reverse sun gear. The cylindrical thrust bearing and the Race, A/T Power Train are two distinct parts and are imported separately.

Part # MD951797 Race, A/T Clutch (Attachment V)

This part is a component of the clutch assembly of an automatic transmission. The Race, A/T Clutch provides a smooth, hard, non-moving surface for cylindrical thrust bearing to ride on. This part works with the cylindrical thrust bearing to reduce friction between the forward clutch and the overdrive clutch.

The applicable subheading for Part # MD704936 Race, A/T Brake, Part # MD735063 Race, A/T Power Train, Part # MD951797 Race, A/T Clutch will be 8482.99.2560 Harmonized Tariff Schedule of the United States (HTS), which provides for inner or outer rings or races for other cylindrical roller bearings. The rate of duty will be 5.8% ad valorem.

It is the opinion of this office that Part Numbers MD704936, MD735063, and MD951797, as races for cylindrical roller bearings, would be subject to anti-dumping margins under current orders of the Department of Commerce related to anti-friction bearings. Please contact your local port for the specific case numbers and margins. If you desire a binding ruling on the applicability of anti-dumping duty to your product, please write directly to the Office of Compliance, Department of Commerce, Washington, D.C.

The applicable subheading for Part # MR336788 Race, A/T One Way Clutch and Part # MD715387 Race, A/T Clutch will be 8708.93.7500 Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Clutches and parts thereof: For other vehicles: Other. The rate of duty will be 2.5% ad valorem.

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 Robert DeSoucey at 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,

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