The country of origin of bearings

N354169 October 17, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Edward Hayes Leake Andersson 1100 Poydras Street, Suite 1700 New Orleans, LA 70163 RE: The country of origin of bearings Dear Mr. Hayes: In your letter dated September 24, 2025, you requested a country of origin ruling on behalf of your client, EBI Transmission System (Thailand) Co., Ltd. A description of the assembly processes was provided in the submission. The products at issue are a deep groove ball bearing, part number EBT1241, and a tapered roller bearing, part number L44649. The ball bearing consists of outer and inner races that incorporate steel balls, a sealing ring and a retainer. The ball bearing is used in motor vehicles to reduce friction and to support radial and axial loads. The tapered roller bearing consists of a cup, which functions as the outer race, a cone, tapered rollers and a retainer. The tapered roller bearing supports radial and unidirectional axial loads of wheel assemblies used in motor vehicles. With respect to origin, the final assembly of both types of bearings occurs in Thailand using components sourced from China. Prior to the final assembly process of both bearings, rings sourced from China undergo various processes in Thailand, in which the steel rings are transformed into races with precision raceways. Such processes include rough machining, a heat treatment, and various phases of precision grinding, honing and superfinishing processes. To form the ball bearing, a seal ring and balls are mounted into a retainer, which is afterwards mounted into inner and outer races. The components are then hydraulically pressed together, and lubrication is applied as needed. For the tapered roller bearing, rollers are mounted into a retainer, which is subsequently mounted onto a cone. The cone assembly is then mounted into a cup, and the components are hydraulically pressed together. Each finished bearing is subject to an anti-rust treatment and is laser marked. When determining the country of origin for purposes of applying current trade remedies under Section 301 and 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). In this instance, the final assembly processes that occur for both types of bearings would not entail the type of processing required to meet the substantial transformation test. The assembly of the ball and tapered roller bearing is rather simple. Inserting and pressing components does not substantially transform the Chinese components. Instead, we look to the country of origin of the inner and outer races, which CBP has concluded are the essence of anti-friction bearings. See HQ Ruling Letters 562528, dated December 10, 2002, 731968, dated March 19, 1990, and 731969, dated March 19, 1990. Here, steel rings are transformed into races with precision raceways subsequent to the machining, precision grinding, honing and the superfinishing processes that occur in Thailand. Therefore, as the country of origin of the inner and the outer races with precision raceways is Thailand, the country of origin of the deep groove ball bearing and the tapered roller bearing is 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division