The country of origin of wheel bearing kits

N345225 February 12, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Didie Muller Trade Pacific PLLC 700 Pennsylvania Ave SEWashington, DC 20003 RE:  The country of origin of wheel bearing kits Dear Ms. Muller: In your letter dated January 16, 2025, you requested a country of origin ruling on wheel bearing kits, which you filed on behalf of Sling Automobile Bearing (Thailand) Co., Ltd. The items under consideration are a wheel bearing kit containing a ball bearing (Item Number SLK 1860) and a wheel bearing kit containing a tapered roller bearing (SLK1880). Each kit consists of four separate unassembled components, which include a wheel bearing, a flange with associated bolts, a circlip, and a nut. According to the bill of materials submitted with your request, the outer and inner rings with raceways as well as the flange are manufactured in Thailand, starting from the importation of raw materials. Additionally, the grease, anti-rust oil, and packing materials used in the assembly are locally sourced in Thailand. The cage, rolling elements, seal ring, dust cover, bolts, circlip, and nut are of Chinese origin and imported to Thailand for further processing. The production of wheel bearings begins with the importation and cutting of steel pipes to specific dimensions. These pipes are then machined into inner and outer rings using CNC lathes. Following machining, the rings undergo heat treatment to improve their mechanical properties. The rings are then precision-ground to create smooth raceways, followed by superfine grinding to finalize the surface quality. Assembly of the wheel bearings involves installing rolling elements, seals, and greasing. Each assembled bearing is then tested for vibration and clearance to meet quality standards, followed by cleaning, marking, and anti-rust oil spraying. Flange production starts with hot forging, where the raw material is shaped under high pressure to form the basic flange structure. The forged flanges are normalized in a furnace to refine their grain structure, enhancing their overall strength and durability. Shot blasting follows to clean the surfaces, preparing them for further machining. CNC lathes and machining centers precisely turn and drill the flanges, including the creation of detailed features such as splines through broaching. The final steps in flange production involve cleaning, inspection, bolt assembly, laser marking for identification, and applying anti-rust oil for preservation. Each flange is then readied for assembly or packaging. In the final stage, the previously manufactured wheel bearing and flange are packaged together with circlip and nut to form the complete wheel bearing kit. The kits then undergo quality control and testing. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). As previously stated, each kit consists of four unassembled components: the wheel bearing, flange, circlip, and nut. Based on the described manufacturing processes in Thailand of the wheel bearing and flange, the items undergo a substantial transformation from raw pipes/materials into identifiable components. Thus, the country of origin of the wheel bearing and flange with the associated bolts will be Thailand. However, the circlip and nut are not transformed in any way and are separate components in the kit. As such, they will retain their country of origin as China. As a result, the country of origin of the wheel bearing kits will be Thailand and China. 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division