The country of origin of a double flanged wheel hub unit with ball bearings

N346900 April 7, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Didie Muller Trade Pacific PLLC 700 Pennsylvania Ave SE, Washington, DC 20003 RE: The country of origin of a double flanged wheel hub unit with ball bearings Dear Ms. Muller: In your letter dated March 18, 2025, you requested a country of origin ruling on the double flanged wheel hub unit incorporating ball bearings, which you filed on behalf of Hubble Autoparts Manufacturing (Thailand), Co. Ltd. The merchandise under consideration is a Double Flanged Wheel Hub Unit Incorporating Ball Bearings (Part Number 513288), which is used in passenger vehicles. The assembly features an outer flange and an inner flange, which work together to support the wheel and axle connection. The outer flange is typically bolted to the wheel, providing a secure mounting point, while the inner flange connects to the axle, via a splined interface for torque transmission. Between the flanges, the rotating body, which includes the ball bearings, allows for low-friction rotation of the wheel. The assembly also integrates an anti-lock braking system (ABS) sensor, which monitors wheel speed for anti-lock braking functionality. You state that the outer and inner flanges are produced in Thailand from raw steel bars. The bars undergo hot forging, normalizing, shot blasting, turning 1, heat treatment, turning 2 and 3, and drilling. The outer flange then undergoes additional outer diameter grinding, raceway grinding, and superfine grinding. The inner flange undergoes additional splining, raceway grinding, and superfine griding. The outer and inner flanges are then assembled together in Thailand with the Chinese sourced inner ring, steel balls, cage, seal ring, ABS sensor, and bolts. Finally, the unit is greased with the Thai sourced grease and anti-rust oil and packaged for shipment to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). It appears that this office has already ruled on a similar scenario in N346375, dated March 18, 2025. In that ruling, we stated that the splining feature of the inner flange gives the wheel hub unit functionality beyond a mere bearing. Furthermore, we cited HQ rulings (e.g., HQ 562528, dated December 10, 2002), where CBP stated that the country of origin of the wheel hub assembly is controlled by where the races with precision raceways are formed and finished into the articulating surfaces of the flanges and inner ring. Since the flanges in the current ruling are made in Thailand and the spline and raceway components are also grinded in Thailand, the country of origin of the entire wheel hub unit incorporating ball bearings (Part Number 513288) will be Thailand. 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