The country of origin of a double flanged wheel hub assembly with tapered roller bearings.

N351266 July 29, 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 a double flanged wheel hub assembly with tapered roller bearings. Dear Mr. Kenkel: In your letter dated July 11, 2025, you requested a country of origin ruling on a double flanged wheel hub assembly with tapered roller bearings on behalf of Pearl Machine (Thailand) Co., Ltd. The articles under consideration are wheel hub assemblies with tapered roller bearings, Models 515061 and 515107, which are used in passenger vehicles. There are holes or bolts on the spindle and outer ring, which can be directly connected to the wheel rim and support the vehicle while enabling smooth rotation of the wheels. Models 515061 and 515107 are equipped with anti-lock braking system (ABS) rings, which are integrated with ABS sensors in modern vehicles. 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. You state that the outer rings and spindles are produced from the forging stage in Thailand, while the inner rings (in a rough, semi-manufactured state) are imported from China. The inner rings are precision machined in Thailand by multiple precision turning operations, drilling or tapping, grinding, and super-finishing, to create a finished product. Only after the above procedures is a precision raceway produced. Other components, such as bolts, are made in Thailand. The rollers, cages, sealing rings, senor, senor rings are made in China and imported to Thailand for inspection and final assembly. In Thailand, the components are assembled together using superfinishing machines, component optical matching machine, press machines, and a spin riveting machine. After that, the wheel hub assemblies are inspected, laser marked, rust-proofed, tested, and packaged for shipment. 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). In this instance, the final assembly of the wheel hub units at issue is not complex enough to render a substantial transformation. The components do not change the shape, character or predetermined use. Thus, like the bearings in Headquarters Ruling Letters 731968, dated March 19, 1990, 731969, dated March 19, 1990, and 562528, dated December 10, 2002, we look to the country in which the rings become races with precision raceways to determine the origin, as they are the essential components of anti-friction bearings. Here, the inner ring of Chinese origin and the outer ring of Thai origin are transformed into races with precision raceways in Thailand. Accordingly, the country of origin of the wheel hub assemblies, Models 515061 and 515107 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, James Forkan Acting Director National Commodity Specialist Division