The country of origin of a track roller

N348424 May 15, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Giada Zamboni Berco Spa Via I Maggio 237 Copparo 44034 Italy RE: The country of origin of a track roller Dear Ms. Zamboni: In your letter dated April 30, 2025, you requested a country of origin ruling. The merchandise under consideration is identified as a track roller, model number RI0103A, which is described as an assembly used in the undercarriage of an excavator. Its main components include a central supporting shaft, a roller shell body, a seal group, and bushings. The function of the track roller is to support and distribute the weight of the excavator, and to guide the tracks as the machine moves. The subject track roller is assembled in Italy and requires a roller shell, a roller shaft, a plug, brackets, bushings, seal rings, O-rings, and pins. All the components are sourced from China except for the plug, O-rings, and pins, which are sourced domestically. The Chinese components arrive in Italy ready for assembly. The roller shell, bracket, and shaft are introduced into an automated assembly line in Italy where they are washed and dried. From here, the assembly process is separated into three sections. The first section has three stations and centers around the steel roller shell, which is described as the main wear-resistant surface where the track engages with the rollers. At the first station, bimetallic bushings are pressed into the roller shell. Next, a dedicated robot inserts the roller shaft through the central axis of the shell. At the last station, a gripper mechanism installs O-rings into grooves on opposite ends of the shaft. The next section prepares the subassemblies that are installed on the axial ends of the roller shell. An O-ring is installed onto a metal seal ring to create a seal group. The seal group is then pressed onto a bracket that functions as both a housing for the seal group as well as the mounting interface of the track roller to the frame of the machine. The subassemblies are then pressed onto each end of the roller shell assembly and pins are inserted to lock the brackets to the roller shell. Lastly, the assembly is filled with oil, the oil plug is installed, and the track roller is painted. When determining the country of origin for purposes of applying current trade remedies under Section 301, and any additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. In viewing the information provided with your submission, nearly all of the components for the track roller are sourced from China. They arrive in Italy with a pre-determined end use as parts and components of a track roller. None of the Chinese components are substantially changed by the addition of the O-rings, pins, and plugs, nor are the assembly operations complex enough to transform the components into a new and different product. Therefore, the country of origin of the track roller, part number RI0103A, is 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division