The country of origin of 3rd generation wheel hub assemblies

N349600 June 25, 2025 OT:RR:NC:N2:206 CATEGORY: Origin John Kenkel International Trade Law Counselors, PLLC 8647 Richmond Hwy, Suite 623 Alexandria, VA 22309 RE: The country of origin of 3rd generation wheel hub assemblies Dear Mr. Kenkel: In your letter dated May 29, 2025, you requested a country of origin ruling on the 3rd generation wheel hub assemblies, which you filed on behalf of Viet Nam Haiya Technology Co., Ltd. The articles under consideration are 3rd Generation Double Flanged Wheel Hub Assemblies (Model Numbers F-616212-S, F616206-S, J-61672, and J-616460 ), which are used in passenger vehicles. Models F-616212-S and F-616206-S contain ball bearings and Models J-61672 and J-616460 contain tapered roller bearings. In all models, the flange end face is provided with a hole and a bolt, which can be directly connected to the wheel rim. In Models F-616206-S and J-616460 the flange inner hole is provided with the spline slot, which can be used with the constant velocity (CV) axel half shaft. These products reduce friction between moving parts of a vehicle, helping to improve fuel efficiency, reduce noise and extend the life of other components, ensuring optimal performance, safety, and comfort on the road. The wheel hub assemblies are equipped with anti-lock braking system (ABS) sensors, which enhance braking precision and safety. The sub-assemblies include an inner flange, outer flange, inner ring, steel ball/tapered rollers, cage, ABS sensor, gear ring, bolts, and other accessories. You state that the inner and outer flanges and inner rings are imported from China and shipped to Vietnam. In Vietnam, the unfinished flanges are fully processed by multiple precision turning operations, drilling or tapping, grinding, and super-finishing, to create a finished product. The inner rings also are fully processed from an unfinished state through multiple grinding, super-finishing, and other manufacturing processes to produce the precision raceways. Components such as bolts and grease, as well as paper boxes, cartons, and other packaging materials are made in Vietnam. Other accessories such as balls (rollers), cages, seals, gaskets, sealing shield, dust covers, ABS rings, and ABS sensors are all made in China and imported to Vietnam for inspection, processing, and final assembly. In Vietnam, the components are precision machined, assembled together using ball automatic assembly machines, hydraulic presses, grease pump machines, bolt presses, and riveting machines (if applicable). After that, the wheel hub assemblies are inspected, laser marked, rust-proofed, tested, and packaged for shipment to the United States. 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). The final assembly of the Chinese components in the present case does not appear to be complex; however, the outer flange and inner ring become races with precision raceways in Vietnam. Pursuant to decisions in Headquarters Ruling Letters 731968, dated March 19, 1990, 731969, dated March 19, 1990, and 562528, dated December 10, 2002, a bearing undergoes substantial transformation in the country where rings become races with precision raceways. Although the wheel hub assemblies in the instant scenario are not mere bearings, the function of Models F-616212-S and F616206-S is to reduce friction and to allow the wheel to be mounted on the axle. Furthermore, the splining feature in Models J-61672 and J-616460 gives the wheel hub a functionality beyond a mere bearing. It allows the wheel hub to mesh with the drive axle to transmit torque. Since the outer flange and inner ring become races with precision raceways in Vietnam, the splining is done in Vietnam, and drilling of the bolt holes also occurs in Vietnam, the country of origin of the 3rd Generation wheel hub assemblies (Model Numbers F-616212-S, F616206-S, J-61672, and J-616460 ) will also be Vietnam for marking purposes. 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, (for) Steven A. Mack Director National Commodity Specialist Division