The tariff classification of Clutch Release Bearings from Brazil

NY K84894 April 14, 2004 CLA-2-87:RR:NC:MM:101 K84894 CATEGORY: Classification TARIFF NO.: 8708.93.7500 Mr. Stephen L. Gibson Sonnenschein Nath & Rosenthal LLP 1301 K Street N.W. Suite 600, East Tower Washington, D.C. 20005 RE: The tariff classification of Clutch Release Bearings from Brazil Dear Mr. Gibson: In your letter dated March 31, 2004 you requested a tariff classification ruling on behalf of your client INA USA Corporation. You submitted brochures and technical drawings of Clutch Release Bearings for motor vehicles. In your description of the articles you state that a clutch release bearing is one of the principal components of a vehicle clutch assembly, which is used to engage/disengage the power from the engine to the transmission. The clutch release bearing transfers the effort of the vehicle operator from the clutch pedal to the clutch during gear changes and allows the engine to continue rotating while the gears are being changed. The clutch release bearings that are the subject of this ruling request are specifically designed and used as parts of clutch assemblies for automobiles. The subject articles consist of two basic parts, namely an angular contact bearing and a plastic housing, which are combined into a single unit. While not all clutch release bearings are outside the scope of HTS Heading 8482, the Release Bearings here are “housed” and fall within HTS Heading 8483. Accordingly, if principally used with the vehicles of Chapter 87, then they are classified in Heading 8708. The applicable subheading for the Clutch Release Bearings 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 646-733-3008. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division