MARTINEZ, SANDRA On behalf of NCSD, welcome to today's webinar.
I'm Sandra Martinez and I asked 102 and the associate I work with is Janet 2.
Today, I'll be presenting a commodity specific webinar on mechanical bearings,
specifically bearings, classified within headings 8482 and 8483.
I will also get into the classification of wheel hub units with bearings.
MARTINEZ, SANDRA You can also confer with the license broker
or a trade attorney, and you can also do your research
of the article researching rulings and cross and decisions from court cases.
MARTINEZ, SANDRA You actually may find the answer you're looking for,
or explanations of how we arrived at the classification
and even sometimes you will see that we revisit the classification
we originally arrived at because of technology or our consideration
of technology articles that are mechanical in nature can change,
and this can affect classification.
MARTINEZ, SANDRA So even after doing your due diligence
of conducting research, you may still find that you're unsure
about the classification.
MARTINEZ, SANDRA Uh, and if it's for a perspective shipment,
you can submit a request for a ruling using our E rulings program,
19 CFR Part 177 explains what the ruling program is about,
what information is required when filing a ruling and other ruling topics.
Now, since we're on the topic of submitting a request for a ruling,
I do wanna mention that when you submit a request, it's always best to send in
as much information as possible.
MARTINEZ, SANDRA Uh, for instance, with bearings and other machines.
It's a good idea to submit technical drawings that are labeled pictures
or photographs of the item in its application.
A breakdown of the material composition and a thorough description
of how the item functions.
I personally like to see a step by step explanation of its method
of operation, but the point is the more information you present,
the better we can understand the good.
MARTINEZ, SANDRA Which is important when classifying.
It's always interesting to me when I receive a request
that just has a picture of the item and it just says, you know,
generally how the item is used.
MARTINEZ, SANDRA Here's our disclaimer
for usages of I'm sorry for usage of images and media.
This particular webinar has public domain images that are included
for educational purposes only.
MARTINEZ, SANDRA So let's jump into the webinar material.
Mechanical bearings are part of our everyday lives
and we really don't notice them, but you'll find them
in almost every machine you can think of.
They trace back to the Egyptians who used them to move huge stones
to build pyramids.
Of course those bearings were thought to be more like plain shaft bearings,
which we will get into.
But in regard to their history, it wasn't until the industrial revolution
that we would see bearings with roller elements.
MARTINEZ, SANDRA Today both types of bearings play a pivotal role in
how machines work, particularly since they improved the operation
and longevity of machines.
MARTINEZ, SANDRA So I mentioned that there are different types
of antifriction bearings actually for classification purposes.
There are two types.
MARTINEZ, SANDRA Those that use a rolling mechanism to reduce friction
and bearings that do not incorporate roller elements,
but instead they have a surface with oil or a fluid,
and then that creates a smooth sliding surface.
MARTINEZ, SANDRA In classifying articles, we apply the general rules
of interpretation the Gris, and we begin with GRI, one which,
for legal purposes, states the classification
of articles shall be determined according to the terms of the heading.
Any relative section or chapter notes, and unless otherwise stated according
to the remaining gerris, in order the first type of bearing,
we will look into our bearings that are classified within.
MARTINEZ, SANDRA Heading 8482, which, if you think
in terms of the heading, provides for antifriction ball or roller bearings,
it should be recognized that these bearings are not housed or installed
into a frame.
Those types of bearings are classified somewhere else outside of heading 8482.
MARTINEZ, SANDRA Here's an explanation of the critical components
that make up a bearing.
You have the inner and outer races.
These are the surfaces or tracks where the rolling elements make contact.
As you can see, the inner race is the smaller of the two.
You also have the cage which is referred to as a retainer.
The retainer functions as a holder for loose rolling elements.
MARTINEZ, SANDRA And it keeps the roller elements positioned
or aligned along the races.
MARTINEZ, SANDRA It also functions as a separator
that provides the required spacing.
MARTINEZ, SANDRA You will also see rolling elements installed
between the races, which in this picture are ball elements.
The configuration of the element changes with roller bearings.
MARTINEZ, SANDRA There are additional components that may be used
with bearings.
For instance, there's a shield which prevents larger particles from entering,
and it also keeps the grease within, and you can see a circlip
which keeps the shield in panel in place.
A very common place where you will find bearings
with the shield is a bicycle and those.
MARTINEZ, SANDRA Well, some of those are called cartridge bearings.
The interesting part about cartridge bearings is there are constructed
to be a complete unit and that cannot be adjusted or fully dissembled.
But the good news about that is that there are fairly inexpensive
and so this balances out there inability to be deconstructed.
MARTINEZ, SANDRA Ohh, by the way, some bearings have seals
which are not pictured here and seals are used
to keep like the finer particles from entering.
MARTINEZ, SANDRA So function wise there are two primary ones.
They reduce friction and they fix guide or hold components
in place while they are transferring or modifying energy.
This makes sense because the job of a bearing is to provide support
to rotating shafts or machine parts while simultaneously allowing them
to have free and smooth movement.
MARTINEZ, SANDRA So bearings are used in most machines
or applications where there's a shaft.
In addition, they're used in applications where energy is created,
machining is done, and materials are created.
MARTINEZ, SANDRA And so I want to mention that
because there are a variety of applications for bearings,
you know it's no surprise that they can be made of material other than metal.
MARTINEZ, SANDRA So, like for practical reasons, a plastic bearing
may be used in saltwater applications due to harsh chemicals.
MARTINEZ, SANDRA Uh sapphire bearings have been used in watches
and with sensitive measuring instruments such as compasses and gyroscopes.
MARTINEZ, SANDRA The advantage with this is these bearings are used
in high accuracy capacities as they tend to be small in size and weight.
MARTINEZ, SANDRA And because they're small in size, they can be brittle,
and for that reason you might find them used with a housing.
MARTINEZ, SANDRA And in addition, bearings can be made
of ceramic material which are used in these high temperature applications,
but as ceramic ball bearing is not the same as a metal bearing
that has been coated with a ceramic material.
MARTINEZ, SANDRA Nevertheless, bearings can also be a bronze
or copper materials.
However, the most common type of material
to manufacture bearings is steel.
MARTINEZ, SANDRA So let's talk about the method of operation.
For ball or roller bearings.
Basically the balls or rollers move within the races.
It's the balls or rollers that endure or bear the load,
and this allows the bearing to spin smoothly,
which in turn allows the components or the machinery parts
to which they're installed onto to to rotate or move
in their appropriate motion.
MARTINEZ, SANDRA So here we have 4 main questions to ask
when classifying bearings.
Does the bearing support an axial or radial load?
MARTINEZ, SANDRA Does the bearing have linear or roller motion?
MARTINEZ, SANDRA What is the material composition of the bearing
and what are the dimensions of the bearing?
MARTINEZ, SANDRA So in the previous slide I just mentioned
that the dimensions of a bearing are needed for classification purposes,
particularly some of the subheadings.
Here's a diagram that explains how the outside diameter,
width and internal diameter are measured.
They're pretty basic measurements that you can use with a ruler,
but for more accurate measurements you can use a vernier caliper,
but of course the manufacturer should be able to provide these dimensions.
MARTINEZ, SANDRA Very often the bearing has a specific application
and will have been designed to fit that application so.
MARTINEZ, SANDRA You know the manufacturer
should have that technical information for you.
MARTINEZ, SANDRA The subheading breakouts within heading 8482 began
with ball bearings.
With integral shots, integral shot bearings
are generally double row bearings.
The shaft function as an inner race of the bearing
or typically the inner race, is machine directly onto the surface
of the internal shaft.
This is different from conventional bearings within a races.
These types of bearings were originally used with water pumps of motor vehicles.
MARTINEZ, SANDRA But they can now be found in other types
of pumps and machines.
You may even find them used in a track system of our garage door.
MARTINEZ, SANDRA So ball bearings without an integral shape
or provided for within subheading 8480, two 10:50, and they're classified
by their configuration.
Now some headings will require the measurement of the outside diameter
as I mentioned, but they'll call for it in millimeters.
So if it they give you that information in inches, you'll have
to make the conversion.
MARTINEZ, SANDRA OK.
And following the sequence of the 8482 subheadings,
we now have subheading eighty 480-210-5004, which is a specifics
of heading that provides for unground ball bearings.
It's typically the races that have not been grounded,
I'm sorry, grinded or hardened with these types of bearings.
It's our understanding that the Raceway is a critical load bearing service
and it's the section of the bearing that's significantly.
MARTINEZ, SANDRA Impacts how it functions.
One way to know if you have an unfinished varying
is when you look at it.
It kind of has a dull finish.
They're not polished looking and you can find them
in less demanding applications such as bicycles, lawn mowers,
shopping carts, and even casters.
MARTINEZ, SANDRA So next we talk about thrust bearings,
which are used in places where axial loads predominate,
such as the propellers of ships.
So when you think about the propeller, it makes sense
that a thrust bearing is used because they turn and they push the ship forward
with massive thrust acting on the propeller shaft,
the thrust ball bearing reduces friction.
MARTINEZ, SANDRA And it minimizes the wear on the shaft
and the components that glide on the bearing.
MARTINEZ, SANDRA And these are the different types of thrust bearings.
You have the flat race, a single direction
and double direction thrust barbarian.
The type that will be used really depends on the application,
and that can range anywhere from vehicle gearboxes
that use helical gears, turbines, industrial machinery to machinery used
in mining and construction.
Thrust bearings have also been used with radio.
MARTINEZ, SANDRA Antenna masts.
It helps reduce the load on the antenna rotator.
MARTINEZ, SANDRA Next, we have linear ball bearings classified
within subheading 8482.
Ten 5012.
They're designed to support loads that move along a straight line.
MARTINEZ, SANDRA These bearings are normally used in precision machinery,
medical instruments, agriculture equipment,
and automated production equipment,
and this makes perfect sense because machines in these applications
often have a forward and backward motion.
MARTINEZ, SANDRA I will say that these types of bearings,
from my understanding, are not too too too challenging to install
and they require minimum maintenance.
MARTINEZ, SANDRA Here's another type of linear ball bearing, also
known as linear motion guides.
These types of linear ball bearings are guideways,
and they provide linear motion by recirculating rolling elements
between a profiled rail and a bearing block.
They can be used with overhead transport systems, gantry robots,
machine tool, table tops, and even linear actuators.
MARTINEZ, SANDRA OK, moving through the subheading sequence.
Uh, next of topic or angular contact bearings.
The uniqueness of these bearings are that they accommodate radial
and axial loads.
They're considered to be directional.
MARTINEZ, SANDRA They're known as spindle bearings, and they tend
to have a high speed rating.
They're designed so that the weight of the load is transferred
from one shoulder to the other through the balls along specific contact angles.
You can see this with the raised shoulders that are highlighted
by the blue arrows in the picture.
The angle of the contact in both the inner and outer race is the same.
MARTINEZ, SANDRA And so because of their configuration,
they're not intended to intended to be like dismantled,
but instead they're replaced.
And applications for these types of bearings are.
MARTINEZ, SANDRA We all have units of automobiles.
Uh vacuum pumps, centrifuges, tool spindles and heavy machinery.
MARTINEZ, SANDRA And of course, you can probably find them in bicycles.
MARTINEZ, SANDRA Radio ball bearings are classified
between subheadings eighty 480-210-5032 and 8482 ten 5064 radio ball bearings
typically transfer transfer radial loads to the access of the shaft.
They are known to be the most common type of bearing since they are versatile
and they can tolerate higher speeds and also because they're pretty durable.
MARTINEZ, SANDRA There are two basic types of radial ball bearings.
You have the non filling type, the Conrad type or the maximum capacity type
and the full capacity types of bearings are filling slot bearings
that have raises that allow for more balls to be loaded.
MARTINEZ, SANDRA Whereas the Conrad ball bearings, also
known as deep groove ball bearings, they can tolerate higher load ratings,
but they're less tolerant of misalignment between the raises.
These types of bearings are assembled by offsetting the inner
and outer races so that their races touch it one point and then
on the other side you have a gap and the ball elements are inserted
into the large gap.
MARTINEZ, SANDRA And distributed around the bearing assembly.
MARTINEZ, SANDRA The act of distributing the balls
uh causes the inner and outer races to be concentric now.
MARTINEZ, SANDRA If the ball elements were left to move freely,
the balls could resume their offset locations
and the bearing could basically disassemble itself and so
for this reason you'll find a cage is inserted and tends to be riveted
in place to hold the balls, and they're distributed positions.
MARTINEZ, SANDRA So we're now pivoting from ball bearings
to roller bearings.
Roller bearings do have the same function as ball bearings.
The biggest difference between the two is the shape of the roller elements.
For roller bearings, the roller elements can be needle,
spherical and even cylinder shape.
These types of bearings can carry heavy loads when dealing
with misalignments and shaft deflections.
And so that's why they're often used with like power machines.
MARTINEZ, SANDRA The reason being is that the design allows for loads
to be distributed over large surface compared to the ball bearings.
MARTINEZ, SANDRA Therefore, they can handle heavy combined radial
and thrust loads.
One other way that ruling roller bear is differ from ball bearings,
and that it's that it's more likely that they can be.
MARTINEZ, SANDRA Disassembled and their parts can be replaced
when compared to ball bearings.
MARTINEZ, SANDRA So here are illustrations of roller elements used
in roller bearings.
And of course you can see how they differ in shape
from ball bearings and even each other.
It's important to know the shape of the roller bearing
or the roller element really, as this will determine
which subheading is appropriate as you move along
through these roller bearing subheadings.
MARTINEZ, SANDRA So tapered roller bearings have been around a long time.
Uh, for their race makeup.
They have a cup that functions as an outer race and a cone unit
that has the roller elements and the inner race.
MARTINEZ, SANDRA They're used in motor vehicles
and in particular the wheel hub units of cars and machines.
MARTINEZ, SANDRA In wheel hub units, you can usually find them used
in pairs facing opposite direction.
This way they can bear the thrust loads in both directions.
They are the most common type of roller bearing.
MARTINEZ, SANDRA 01 more thing it should be mentioned
that there is a subheading breakout when the cup
and cones are entered as a set and a separate subheading
for when the cone is entered separate from the cup
and the Cup when entered separate would be classified as a part.
MARTINEZ, SANDRA Spherical roller bearings, as their name indicates,
have spherical or barrel shaped rollers.
The 10 digit classification is determined
on whether the bearing is a single row or not.
These bearings are particularly useful in supporting a rotating shots
that is inserted into the bore of the inner ring and maybe misaligned
with regards to the outer ring and featuring this capability,
you know it's no surprise that these types of bearings.
MARTINEZ, SANDRA Are primarily used in applications
where you have an angular misalignment.
They're designed to resist heavy and shock loads
and so they can even be doubled up to receive the thrust in either direction.
MARTINEZ, SANDRA Needle roller bearings are often used
in motor vehicles and mostly in transmissions
and compressors of motor vehicles.
But to be considered a needle roller bearing for classification purposes,
subheading note 4 to chapter 84 must be met.
The note is for bearings with cylindrical rollers.
However, the cylindrical rollers must have a uniform diameter
that does not exceed.
MARTINEZ, SANDRA 5 millimeters and it features a length
that is at least three times the measure diameter.
MARTINEZ, SANDRA If these parameters are met,
the cylindrical bearing can be classified
within subheading eighty 480-240-0000.
And if you think about it, it makes sense
because it's these measurement parameters that allow the rollers
to be elongated.
MARTINEZ, SANDRA Now.
MARTINEZ, SANDRA If the cylindrical roller does not meet the specifics
of Note 4 to chapter 84, the bearing would be classified
in subheading eighty, 480-250-0000, which provides
for other cylindrical bearings.
MARTINEZ, SANDRA Umm, usually.
Cylindrical bearings can only manage a limited amount of thrust load,
and this is an operational difference between the cylindrical
and needle roller bearings, which can handle very high radial loads.
MARTINEZ, SANDRA OK, parts of bearings.
So when classifying parts of bearings and for that matter any machine
of chapter 84, we look to Note 2 to section 16 and we apply it
in a hierarchy manner and it's simplest version part A to Note 2 says that
if an item is provided for Euro nominee or has a function that meets the terms
of the the heading then the item should be classified in its respective heading.
MARTINEZ, SANDRA If the item is not specifically provided for
and no data is not applicable, we then fall to note B, which says
if the item is specifically or principally used with a particular kind
of machine, then it's classified as a part within that heading.
MARTINEZ, SANDRA So when you're considering parts or components
of an antifriction bearing, we don't usually have to go further than OB,
but I've included it note C just to give you a complete view
of the note.
It's always good to understand these notes in their entire team.
MARTINEZ, SANDRA So with parts of bearings,
a subheading 8482 ninety one provides for.
MARTINEZ, SANDRA Balls, needles and rollers.
MARTINEZ, SANDRA But with a steel ball elements,
a deeper consideration has to be taken because of note 6
to chapter 84, which states that for steel balls the maximum
and minimum diameters can differ from the nominal diameter by more than 1%
or by more than .05 millimeters whichever's less.
Otherwise it's excluded from being classified
as a part within heading 8482.
MARTINEZ, SANDRA Just a side note, uh,
a nominal ball diameter is the value used
to make like a general identification of the ball size.
Nevertheless, in case you're asking yourself,
where would I get that information?
Well, that's something that the manufacturer will probably have
to provide.
It ties into the molding specs of the ball
and the manufacturer will be the party to have that information.
MARTINEZ, SANDRA So subheading 84, eighty 299 provides for the inner
and outer races, including the cups for tapered roller bearings.
MARTINEZ, SANDRA Other components that are classified
within the subheading are cages and fixing sleeves.
MARTINEZ, SANDRA Oh, just one thing.
Uh vulcanized rubber seals are excluded from heading 8482.
Well, all of Chapter 84 based on note 18 to section 16.
MARTINEZ, SANDRA So as I mentioned, fixing sleeves
for bearings are classified as parts of a bearing.
MARTINEZ, SANDRA Uh, why, right?
Why would those?
They're not actually any of the parts that I showed you earlier wired.
Those considered parts of a bearing.
Well, ruling 967092 gives us some insight by explaining
that fixing sleeves are used to mount and help align bearing
when mounted onto a shaft.
It's thought that they basically assist in the positioning
and operation of a bearing.
MARTINEZ, SANDRA And so, because of this, uh, fixing sleeves are considered
to be parts of a bearing for classification purposes though.
MARTINEZ, SANDRA OK, we've now arrived to the aspect
of the presentation that discusses bearing housings, house bearings
and plain chef bearings, which are all classified within heading 8483.
MARTINEZ, SANDRA Subheading 8483.20 provides for house bearings.
These are bearings that are pressed or inserted into a housing or frame.
They come in different shapes and configurations.
I've even heard them refer to as cartridges.
MARTINEZ, SANDRA On and.
So that's why you have the the two breakouts,
one or for the more common one,
and the ones that in case you know, they've come
in some other configuration.
MARTINEZ, SANDRA And So what is the purpose of a housing for a bearing?
Well, they support the motion of the bearing and they act
as a customized mounting for it.
It also protects the bearing from contaminants, and this is beneficial
because it extends the life of the bearing.
MARTINEZ, SANDRA So here are some pictures
of bearing housings.
MARTINEZ, SANDRA Me and my pointer here.
Uh, this upper left picture.
MARTINEZ, SANDRA Is to give you an idea of
what a flange housing would look like, and over here
on the upper right picture we have a take up housing.
MARTINEZ, SANDRA And on this bottom left, right here.
MARTINEZ, SANDRA We have a pillow block housing
and right here the bottom right picture is that
of a miniature pillow block housing.
MARTINEZ, SANDRA Here's a cutaway illustration.
MARTINEZ, SANDRA That depicts what a housing with a bearing looks like
if taken apart or dissembled.
I really like this one because you can see the bearing separate
from the housing.
The housing itself is not functioning as a race for the bearing,
and this is what makes it differ from a wheel hub unit,
which we'll get into in just a bit.
But I mean, you can clearly see that the bearing is separate from the housing.
MARTINEZ, SANDRA Ohh, by the way, you can also see a fixing sleeve
which here is referred to as an adapter.
MARTINEZ, SANDRA So these subheadings listed in this slide primarily provide
for only the bearing housings.
In other words, there's no bearing press inside.
However, subheading 8483 thirty 80 does have a statistical breakout
for housings with plain shaft bearings.
MARTINEZ, SANDRA OK, plain shaft bearings.
Plain shaft bearings are also referred to as slide contact bearings,
sleeve bearings, journal bearings, or even by the trade term bushings.
They typically consist of rings of metal or even other materials
such as plastics.
They can be in one piece or in several pieces clamped together using oil
or fluid.
Their function is to form a smooth bearing surface.
MARTINEZ, SANDRA In which a shaft or an axle turned.
MARTINEZ, SANDRA Keep in mind that this heading does not include graphite
or other carbon bearings of heading 6815.
This is because, note one to chapter 84 excludes machinery.
MARTINEZ, SANDRA And This is why they're less prone to fatigue compared
to ball or roller bearings whose rolling elements are, you know,
in constant contact with the.
MARTINEZ, SANDRA Whatever the component
or part they're being used with.
MARTINEZ, SANDRA Uh, so early in the presentation, I mentioned
that we classify parts of machines that are classified
in Chapter 84 according to Note 2 to section 16 and parts
that are integral and identifiable to bearing housings and plane chef.
Bearings are classified within subheading 8483.90
One important exception is complete baller rare or roller bearings
as they fall within heading.
MARTINEZ, SANDRA 8482.
MARTINEZ, SANDRA It makes sense.
We just talked about this, those types of bearings fall
within heading 8042, so.
MARTINEZ, SANDRA And and this makes sense because it falls
in line with note 2A to section 16 and also additional US rule
of interpretation.
One seat which States and relevance that are provisioned for parts are parts
and accessories does not override a specific provision for such part
or accessory.
MARTINEZ, SANDRA OK, we'll help units.
What are wheel hub units and how are wheel hub units
that incorporate bearings classified?
MARTINEZ, SANDRA Well, we'll hub units
incorporating antifriction bearings
are used in motor vehicles or industrial vehicles,
and they're typically located between the brake drum and the axle.
And for consideration of heading 8482, their purpose
is to incorporate bearings.
MARTINEZ, SANDRA And their primary function is to.
MARTINEZ, SANDRA Reduce friction allowing for a smooth steering action.
MARTINEZ, SANDRA Here we have an illustration of a wheel hub unit
that incorporates bearings and you can see that the unit is connected
to the hub carrier and in turn a CV joint.
So if you're reading this drawing from left to right
and following the large blue arrows, you can see that the hub has an outer
and inner bearings that are incorporated within.
MARTINEZ, SANDRA You know, overall, I really wanted to give you an idea
of their connection and and and how they work and how they're in
and where they're installed.
MARTINEZ, SANDRA So for classification purposes, it's thought
that wheel hub units, even with flanged outer and inner bearings,
are simply bearings that are enhanced so that the bearings
within can be mounted and connected to their appropriate components
as a complete unit.
Their primary function is to minimize friction.
MARTINEZ, SANDRA Uh, we all have units of industrial vehicles
and motor vehicles.
Even generations 1/2 and some generation three are simply bearings
that have been modified.
MARTINEZ, SANDRA Uh, in ways that allow them to facilitate the mountings
of the bearings, they tend to be a single unit, not bearings pressed
into a frame.
MARTINEZ, SANDRA Like the UM house bearings.
Therefore, if the wheel hub units have no additional features beyond that
of facilitating their ability to be mounted, they are classified
within heading 8042, which is unlike a house bearing which we saw earlier,
where you have again where you have.
MARTINEZ, SANDRA Uh.
A bearing or bearing with separate races that is pressed
into his separate housing.
The housing itself is not acting.
MARTINEZ, SANDRA Umm, like the inner or outer race of the bearing?
MARTINEZ, SANDRA While in case you're wondering
what features would exclude a wheel hub unit from being classified
within heading 8482, here we have a hub and I've heard this type
being called a wheel bearing that features an ABS sensor connector
and if you notice it also has splining or teeth that mesh
with the teeth of a shot that's intended to transmit power.
The Splining is particularly found with.
MARTINEZ, SANDRA We'll have units that are for driven wheels.
It's what allows the splined axle to marry up with the wheel hub unit.
MARTINEZ, SANDRA So these are features
that give the hub unit functionality
beyond that of just minimizing free friction.
It's what makes it a part of like the breaking system or the steering system.
And heading 8482 simply provides for anti friction bearings.
So this type of hub would be excluded from 8482.
MARTINEZ, SANDRA So what about a wheel hub unit like this one?
It's for a motor vehicle and you can see that the ABS sensor is in present.
MARTINEZ, SANDRA Well, it too would be excluded
because as I mentioned, the teeth right in the center are features
that relate to the transmission of power.
And we know that such functionality doesn't fall in the scope of 8042.
MARTINEZ, SANDRA But does it fall outside of heading 8483?
You might be thinking about this because you know it does transmit power.
MARTINEZ, SANDRA So doesn't that meet the terms of heading 8483?
MARTINEZ, SANDRA Well, it doesn't.
It would be excluded.
It's thought that the splining makes it part of the, you know,
the steering or the driving system, whether it's for an industrial vehicle
or motor vehicle and in particular for a motor vehicle, it's very clear why,
because if you recall DRI one, it says that we have
to consider any relative section or chapter nodes.
And in this case we consider note 1L to section.
MARTINEZ, SANDRA 16 which excludes articles of section 17.
Motor vehicles are articles of section 17.
MARTINEZ, SANDRA Also, we have explanatory note B to heading 8483
which gives us some guidance.
MARTINEZ, SANDRA And it says that transmission equipment that is described
by the heading.
MARTINEZ, SANDRA Is excluded from this heading, UM if it's designed
for solely or principally with vehicles of section 17.
MARTINEZ, SANDRA Uh, of course, this rule does not apply to internal parts
of vehicle engines, but we know that we'll hub units are not used
in engines of a motor vehicle.
As we mentioned earlier, there used like in the suspension section
of a motor vehicle.
Therefore, if the wheel hub units are used with motor vehicles
and they have functionality beyond that of heading 8482,
they would be classified as a part of it.
MARTINEZ, SANDRA Of that of a motor vehicle.
MARTINEZ, SANDRA Here's a question I see that comes up often
with wheel hub units.
What about wheel hub units which incorporate a bearings that are designed
to be used in a specific motor vehicle or a specific machine?
Aren't those specifically made units classified within heading 8482?
MARTINEZ, SANDRA Well, ruling 960049 gives us some guidance in this ruling.
We have a a discussion, a wheel hub unit that's used on a Lincoln Town car.
The ruling explains that while the wheel hub may be designed specifically
for a Lincoln town car, it's not legally relevant because many ball
or rolling bearing types are manufactured to specific engineering.
MARTINEZ, SANDRA And design criteria and their perches
with a particular application in mind.
So as the wheel hub unit had no additional features, it was classified
within heading 8482, even though it had a particular application.
And this makes sense because if the bearing doesn't have a precise fid
or connection.
MARTINEZ, SANDRA It won't achieve what's intended to do,
which is to minimize friction.
It just wouldn't be able to serve its purpose, so you know,
and it's just known that bearings tend to be manufactured
for specific applications most of the time.
I mean, there are some that can fit more than one application,
but nevertheless it doesn't have any effect on classification.
MARTINEZ, SANDRA OK, so we're coming to the end of the presentation,
but I didn't wanna end without mentioning the open case
for tapered roller bearings.
It's a 570601.
The scope of this case concerns tapered roller bearings and parts
of tapered roller bearings from China.
From I'm sorry from China, the subheading lists.
MARTINEZ, SANDRA The barriers.
MARTINEZ, SANDRA Scopes that may fall under the scope of the case,
but it's the scope language that you wanna pay particular attention to.
It's that information that's used to determine whether a bearing falls
within the scope of the anti dumping case or not.
MARTINEZ, SANDRA So here's the summary of what we discussed today.
Heading 8482 provides for ball or roller type of bearings
that are not housed or installed in a frame.
Heading 8483 provides for house bearings bearing housings
and plane shot bearings.
MARTINEZ, SANDRA And #3 wheel hub units are classified
within heading 8042, provided they have characteristics that fall
within the scope of the heading.
MARTINEZ, SANDRA Of course, if you would like
to hear this presentation again, I've included the link for the webinar
at the bottom of the slide and I think it was included in the chat box.
It will take some time before it gets posted.
It needs to go through its checks so it may take, I don't know,
a few weeks or so, but before you know it, it will be posted.
MARTINEZ, SANDRA OK.
Uh, we reached the end of the presentation.
Does anyone have any questions?
If you do, you can simply type them in the chat box.
MARTINEZ, SANDRA OK, I see where would magnetic bearings be classified?
MARTINEZ, SANDRA In China, certain magnetic bearings
are classified 8483 thirty.
MARTINEZ, SANDRA Umm, it really depends.
I mean, is it housed or are they?
Are they roller type or are they housed or plane shaft?
It's kind of general, I don't I'm not really come across too many
of those types of bearings.
MARTINEZ, SANDRA Should let me see here if I can.
MARTINEZ, SANDRA Their housed with magnets.
MARTINEZ, SANDRA Hum.
MARTINEZ, SANDRA Umm.
MARTINEZ, SANDRA You know I can't picture what those look like.
I mean, I think I think I understand, but I'm, I'm I'm not quite sure.
Would you mind sending me an email with that?
And then I'll take a look and see if you know, that's something that would go.
MARTINEZ, SANDRA They resemble roller bearings.
MARTINEZ, SANDRA That are housed.
MARTINEZ, SANDRA Maybe I need to take a look at it and see
how the the magnets function.
I don't wanna give you any incorrect direction or anything like that.
Just send me an email and I will definitely take a look at that.
MARTINEZ, SANDRA OK.
Does anyone else have any questions?
I don't see anything.
MARTINEZ, SANDRA OK, well, if you have any questions
that you think of later or you prefer to address offline,
here's my contact information emails.
Probably the quickest way to reach me since there are days I do telework.
But before I conclude this webinar, I wanna say thank you
to the NCSD webmasters I worked with Simon a Fong and Amy.
Thanks to y'all, we were able to complete the webinar today
and of course, thank you to everyone for taking time out of your day
to listen in.
MARTINEZ, SANDRA Thanks and have a great day everyone.