The tariff classification of a steering column support from Germany
Active· CBP ruling HQ b80515· Issued 1997-04-21
Ruling text
NY B80515
April 21, 1997
CLA-2-87:RR:NC:1:102 B80515
CATEGORY: Classification
TARIFF NO.: 8708.99.7360; 8483.20.4040
Mr. Stephen L. Gibson
Arent Fox
1050 Connecticut Avenue, NW
Washington, DC 20036-5339
RE: The tariff classification of a steering column support from
Germany
Dear Mr. Gibson:
In your letter dated December 18, 1996 you requested a tariff
classification ruling on behalf of your client INA Bearing Company.
A meeting was held in February to discuss issues raised in your
request and additional information was presented in your letter of
March 11, 1997.
The item in question is identified as INA part number F216217
and is described as a steering column support. You state the
article is designed and used exclusively as part of an automobile
steering column, where its purpose is to provide zero-clearance
location and support of the column's central shaft relative to the
column's housing. The zero-clearance feature dampens vibration and
provides for smooth and consistent rotation of the central column.
Technical drawings depicting the design and use of the column
support and a sample were submitted with the ruling request.
The column support is an assembly consisting of a radial ball
bearing and two plastic rings. The ball bearing consists of a steel
outer shell or casing, a set of split steel rings, a steel spring,
steel balls and an unground inner steel ring. The inner steel ring
serves as the inner race of the bearing, while the set of split
rings, together with the outer shell, forms the outer race.
The two plastic rings, identified as the inner and outer
"tolerance rings", are press-fitted to the bearing and complete the
steering column support assembly. The tolerance rings are
specifically designed to accommodate and compensate for the
multiple tolerances encountered in the assembly and installation of
the steering column into the automobile. Together the plastic rings
provide a housing for the bearing which will facilitate mounting
and impart the desired fit and feel to the steering column
assembly.
The issue raised by your request is whether the steering column support is properly classified under heading 8708,
Harmonized Tariff Schedule of the United States (HTSUSA), as a
part or accessory of a motor vehicle, or under heading 8483, as a
housed bearing.
The classification of merchandise under the HTSUSA is
governed by the General Rules of Interpretation (GRIs). GRI 1,
HTSUSA, states in part that "for legal purposes, classification
shall be determined according to the terms of the headings and
any relative section or chapter notes". The headings in
contention are headings 8708 and 8483, HTSUSA.
Heading 8708 provides for "...(p)arts and accessories of the
motor vehicles of 8701 to 8705..." Heading 8483 provides for
"...bearing housings, housed bearings and plain shaft
bearings..." While both headings appear to describe the column
support, classification must be determined in accordance with
section and chapter notes. Heading 8708 is within Section XVII
and Chapter 87, HTSUSA. Heading 8483 is within Section XVI and
Chapter 84, HTSUSA.
There are three relevant legal notes. Section XVI, Note
1(l), HTSUSA, excludes articles of Section XVII from
classification within Section XVI. Section XVII, Note 2(e),
HTSUSA, states that articles of heading 8483 are excluded from
Section XVII if the articles constitute integral parts of engines
or motors. Section XVII, Note 3, HTSUSA, requires that the term
"parts" in chapter 87 refers only to parts which are used solely
or principally with the articles of chapter 87.
You state that the column support is designed and used
exclusively as part of an automobile steering column. Since the
support is used "solely or principally" with motor vehicles and
motor vehicles are classified in chapter 87, the column support
is a "part" within the meaning of Section XVII, Note 3. Motor
vehicles designed for the transport of persons are classified
under heading 8703, HTSUSA. As a part that is solely or
principally used with articles of heading 8703 the steering
column support meets the terms of heading 8708.
Furthermore, Section XVII, Note 2(e) only excludes articles
of heading 8483 which are parts of engines or motors from Section
XVII. Since the column support is used in a steering assembly and
not with engines or motors, it is not excluded from Section XVII
by Note 2(e).
The steering column support is clearly an article of Section
XVII. Articles of Section XVII are excluded from classification
within Section XVI under heading 8483 by Section XVI, Note 1(l).
The applicable subheading for the steering column support
will be 8708.99.7360, HTSUSA, which provides for "Parts and
accessories of the motor vehicles of headings 8701 to 8705 ...
Parts for steering systems ... Other..." The rate of duty will
be 2.7 percent ad valorem.
It is the opinion of this office that the steering column
support would not be subject to antidumping duties under
Department of Commerce orders relating to antifriction bearings.
In light of recent determinations by Commerce relevant to
automotive components and previous opinions by Customs regarding
unground bearings, we consider the column support to be outside
the scope of the orders. Should you desire a binding ruling on
the applicability of current antidumping duty orders 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 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 Kenneth
T. Brock at 212-466-5493.
Sincerely,
Robert Swierupski
Chief, Metals and Machinery Branch
National Commodity
Specialist Division
Source: rulings.cbp.gov — ruling b80515, retrieved 2026-10-12T05:37:30Z, republished verbatim. This digest is informational; only CBP issues binding rulings.