The country of origin of bearing shells

N355135 November 10, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Segyo Jung Hansung Co., Ltd. 33 Yongdeok-ro, 302 Beon-gil, Hallim-myeon Gimhae-si 50852 South Korea RE: The country of origin of bearing shells Dear Ms. Jung: In your letter dated October 22, 2025, you requested a country of origin ruling on bearing shells. Descriptive information was provided with your submission. Part numbers HFZLQ18-200, HFNLK22-225, and HFNLB28-280 are referred to as bearing shells. Each shell consists of two semi-cylindrical sections (an upper and lower section) in which oil circulates on the surface of the sections once a shaft or axle is inserted into the center bore of the shell. This hydrodynamic lubrication process allows for friction to be minimized and supports the load of a shaft as it rotates. It is noted that at the time of importation, the shell may feature a housing that appropriately positions it within its application, which ranges from electric motors to generators. With respect to origin, the shell is manufactured in South Korea using steel plates from China. In South Korea, the plates are laser cut into U shapes and then machined, grooved, drilled and plated. During the machining processes, the side, inner and outer surfaces are geometrically shaped for concentric alignment. The grooving processes form the lubrication pathways and the drilling processes create the features that allow the upper and lower sections to be affixed to each other. Once the finished upper and lower sections are plated, they are bolted to each other using dowel pins and bolts. Lastly, each bearing shell is inspected and packaged. In instances when the shells are housed, plates from China undergo the same cutting, machining, grooving, drilling, plating and bolting processes in South Korea as described in the scenario above. Afterwards, the bearing shell is inserted into a housing formed in South Korea and is secured in place using an anti-rotation pin. 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 viewing the illustrations submitted, it is subsequent to the cutting, machining, grooving and drilling processes that occur in South Korea that the shell has the converging shape and pathway accuracy that allows for an oil film to be created. In this condition, the plates from China are substantially transformed into a shell that functions as a plain shaft bearing. As such, the Chinese plates are substantially transformed into a new and different article of commerce with a name, character, or use distinct from the plates exported to South Korea. Accordingly, the origin of the bearing shell is South Korea. When the bearing shell is housed, Chinese plates undergo cutting, machining, grooving and drilling processes in South Korea to become a shell that functions as a plain shaft bearing. Afterwards the bearing shell is inserted into a housing from South Korea. Inserting a bearing shell into a housing is a simple process and does not substantially transform the components. Therefore, as the origin of the bearing shell and the housing is South Korea, the origin of the housed bearing shell is South Korea. 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