The tariff classification of bearings from Mexico

N356647 December 19, 2025 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8483.30.8070 Eileen Family Geodis USA, LLC 5101 S. Broad Street Philadelphia, PA 19112 RE: The tariff classification of bearings from Mexico Dear Ms. Family: In your letter dated December 2, 2025, you requested a tariff classification ruling on behalf of your client, Roller Bearings Company of America, Inc. Descriptive information was provided with your submission. The items at issue are referred to as the MS14 spherical plain bearings, part numbers 03-825-03, 03-824-06, 03-826-08 and 03-823-14. The bearings consist of an inner race shaped as a ball, a chamfered outer race and a polytetrafluoroethylene liner that is bonded to the inside diameter of the race. The bearings, which are constructed from steel material, facilitate the pivoting movement of the rotating member and permit load transfer. The bearings are used in aircraft components such as actuators, engines, struts and subsystems such as flight control and landing gear subassemblies. In your submission, you suggest classifying the bearings within subheading 8807.30, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of aircrafts. You support your analysis by stating that the bearings are not integral parts of engines or motors, and cite Note 2(e) of Section XVII, excluding “Machines or apparatus of headings 8401 to 8479, or parts thereof, other than the radiators for the articles of this section; articles of heading 8481 or 8482 or, provided they constitute integral parts of engines or motors, articles of heading 8483” from this Section. We disagree. Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. Additional U.S. Rule of Interpretation 1(c) states that, in the absence of special language or context which otherwise requires, “a provision for parts of an article covers products solely or principally used as a part of such articles but a provision for ‘parts’ or ‘parts and accessories’ shall not prevail over a specific provision for such part or accessory.” The bearings at issue are not aircraft parts, but rather components of different systems within the aircraft, such as flight control systems, landing gear assemblies, and actuation systems. As a result, they are subparts of particular parts. In this regard, we are guided by Mitsubishi Electronics America, Inc. v. United States, 19 C.I.T. 378 (1995), wherein the Court of International Trade discussed whether a clutch is classifiable as a part of an automobile. The court stated “that if the subject merchandise is not a clutch, but rather a part of a starter motor, then it cannot be classified as part of an automobile, even though it is used solely in automobiles. This is because a subpart of a particular part of an article is more specifically provided for as a part of the part than as a part of the whole.” Similarly, the bearings in this case are subparts of systems and parts used in aircrafts. Since plain shaft bearings are specifically provided for within heading 8483, classification of the products within subheading 8807.30, HTSUS, is precluded. The applicable subheading for the spherical plain bearings will be 8483.30.8070, HTSUS, which provides for Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings and plain shaft bearings; gears and gearing; ball or roller screws; gear boxes and other speed changers, including torque converters; flywheels and pulleys, including pulley blocks; clutches and shaft couplings (including universal joints); parts thereof: Bearing housings; plain shaft bearings: Other: Plain shaft bearings: Without housing: Spherical. The general rate of duty will be 4.5 percent ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division