NY 862986: The tariff classification of an unground thrust ringassembly from Great Britain

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

 
                          
                                   NY 862986

                                      May 31, 1991     


CLA-2-84:S:N:N1:102 862986  

CATEGORY:  Classification

TARIFF NO.: 8482.10.5004  

Mr. Thomas J. O'Donnell
Sonnenberg, Anderson, O'Donnell & Rodriguez
200 West Adams Street, Suite 2625
Chicago, Illinois 60606

RE:  The tariff classification of an unground thrust ring
assembly from Great Britain

Dear Mr. O'Donnell:

     In your letter dated April 30, 1991, on behalf of your
client, Drilex Systems Inc., you requested a tariff
classification ruling.         
     
     The item in question is known as a thrust ring assembly.  It
consists of a series of stacked inner and outer contact rings
with rows of steel balls placed between each set of rings.  These
thrust ring assemblies surround the drilling output shaft found
in Drilex's downhole positive displacement motors.  While the
function of this thrust stack, which can contain 19 or more ring
sets, is to reduce rotational friction while providing both
upwards and downwards thrust support, it does so by utilizing
friction.  The metal used in the rings is not hardened to the
same degree as is common in other bearings, and a desired result
of the motor's rotation is to wear down a channel in each of the
races.  This wear, in conjunction with the fact that the balls
are not held in cages (retainers) gives the stack the ability to
laterally displace itself by up to two centimeters.  This
deflection ability allows the thrust assemble to flex in order to
follow the necessary bending movement of the motor/drill through
non-uniform surfaces.

     While your letter presents a number of arguments expressing
your belief that this thrust ring assembly should not be subject
to the current antidumping margins applicable to ball bearings,
one of them is of utmost significance.  The manufacturer provided
detail information on the tolerance levels utilized in the
production of both the balls and the rings.  In the case of the
balls, the maximum and minimum diameters differ by .15mm from the
nominal diameter.  The ring tolerance has a .25mm deviation in
diameter.  As such, based on the Explanatory Notes to the
Harmonized Tariff Schedules, we would consider the thrust rings
to be unground bearings. 

     The applicable subheading for the thrust ring assemblies
will be 8482.10.5004, Harmonized Tariff Schedule of the United
States (HTS), which provides for unground ball bearings.  The
rate of duty will be 11 percent ad valorem. 

     It is the opinion of this office that the thrust ring
assemblies and their parts 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.  The scope of the original dumping
petition concerned itself with "precision" ball bearings and did
not cover ungound bearings.  Should you desire a binding ruling
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
                                   New York Seaport