The country of origin of a housed bearing

N357580 January 26, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Yaping Wang Landing Law Offices 16/F, EastTower Raffles City in the North Bund, No. 1089 DongDaMing Road Hongkou District, Shanghai 200082 China RE: The country of origin of a housed bearing Dear Ms. Wang: In your letter dated January 7, 2026, you requested a country of origin ruling on behalf of SWC Bearings Technology Co., Ltd. The product at issue is part number 701.SCP205-16-GA.41.4GEN, referred to as an insert bearing with a housing. The product, which is specifically engineered for use in the material handling industry, is comprised of a cast iron housing that incorporates a ball bearing, seals, shields, set screws, an oil cap and an anti- rotation pin. The bearing is designed to withstand radial and axial loads and consists of spherically shaped races and caged balls. The housing, which features two mounting holes, functions as an external structure that supports the installation and operational positioning of the bearing. The anti-rotation pin prevents rotational displacement of the outer ring relative to the bearing housing, and the seals and shields prevent ingress of external contaminants. With regard to origin, you explain the product is assembled in Thailand using components sourced from Thailand and China. Prior to the final assembly process, a Thai-sourced housing blank undergoes additional processing in Thailand. It is painted, milled, machined, bored and turned to form oil nozzle holes, and then afterwards, deburred, touched up with paint and cleaned. Also, Chinese manufactured rings, intended to be used as races, are imported into Thailand in a semi-finished state, where the rings undergo superfinishing processes that establish the required tolerances of roughness, parallelism and circularity, in which the rings will afterwards feature ultra smooth surfaces measured in millionths of inches to function as races with precision raceways. The superfinishing processes consist of three phases of grinding in which the surface roughness is enhanced by approximately 75 to 89 percent, and a cessation process in which the circular deviation is improved by 41 to 45 percent. Once the superfinishing processes are complete, the rings undergo ultrasonic cleaning. During the final assembly process, an oil nipple and a cage sourced from China are assembled and installed into the housing. Grease is injected through the oil cap; seals are pressed in place and set screws are installed. Next, a cage sourced from China is riveted, demagnetized and cleaned. Afterwards, balls sourced from China are inserted into the cage. Then, the inner and outer races, caged balls and shields are manually pressed into the housing, an anti-rotation pin is set, and final inspections are completed. 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 (HQ) 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 in Thailand would not entail the type of processing required to meet the substantial transformation test. Inserting and pressing components into a housing is rather simple. Instead, we turn to the country of origin of the ball bearing, which allows the product to minimize friction, and the housing, which supports the bearing’s functionality and accounts for a good portion of the product’s value. For anti-friction bearings, CBP has previously concluded the races are the essence of bearings. In HQ Ruling Letters 562528, dated December 10, 2002, 731968, dated March 19, 1990, and 731969, dated March 19, 1990, CBP explains that the fundamental character and use of an anti-friction bearing is determined after the rings are ground and finished into races with precision raceways such that they are no longer considered rings. Here, inner and the outer races with precision raceways are formed in Thailand. Thus, the origin of the insert bearing is Thailand. Therefore, as the origin of the insert bearing and the outer housing is Thailand, the country of origin of the product, an insert bearing with a housing, 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division