The country of origin and USMCA eligibility of bearings

N358905 March 18, 2026 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Origin, Trade Agreement Rick Van Arnam Barnes, Richardson & Colburn, LLP 45 Broadway, Suite 3130 New York, NY 10006 RE: The country of origin and USMCA eligibility of bearings Dear Mr. Van Arnam: This letter is in response to your submission, dated February 16, 2026, in which you request a ruling on the country of origin of tapered roller bearings on behalf of your client, Fersa-NKE Bearings North America, Inc., for the purposes of applying trade remedies under Section 301 or additional duties. You also inquire whether the bearings are eligible for duty free treatment under the United States-Mexico-Canada Agreement (USMCA). The items under consideration are part numbers HM 212049/11, HM 518445/10, HM 218248/10, 594 A/529A and 580/572, which are referred to as tapered roller bearings (TRBs). The bearings consist of caged rollers, a cone, and a cup with an outside diameter that measures between 102 and 203 millimeters. The bearings are constructed of steel material and are used in heavy duty trucks. We note that USMCA analysis requires a tariff classification of the good. Based on the information submitted, the applicable subheading for the tapered roller bearings will be subheading 8482.20.0061, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Ball or roller bearings, and parts thereof: Tapered roller bearings, including cone and tapered roller assemblies: Cup and cone assemblies entered as a set: Other: With cups having an outside diameter exceeding 102 mm but not exceeding 203 mm. The general rate of duty is 5.8 percent ad valorem. Each bearing is assembled in Mexico using components sourced from Mexico and China. Prior to the final assembly process, rings sourced from China are transformed into races (a cup and cone) with ultra smooth surfaces measured in millionths of an inch to function as races with precision raceways. Such processes include various phases of precision grinding, honing and superfinishing processes. The final assembly process begins by manually or automatically placing Chinese sourced rollers onto the tapered raceway. A Chinese sourced cage is then positioned over the rollers and pressed in place to produce the cone assembly. Afterwards, the cone assembly is inserted into the cup, oil is applied, and then the finished bearing is labeled, coated and packaged. When determining the country of origin for purposes of applying current trade remedies under Section 301 and other duties, 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 processes described above would not entail the type of processing required to meet the substantial transformation test. The assembly of the tapered roller bearings 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 sourced from China are transformed into races with precision raceways subsequent to the grinding, honing and superfinishing processes such that they are no longer rings. Therefore, as the country of origin of the inner and the outer races with precision raceways is Mexico, the country of origin of the tapered roller bearings will be Mexico. The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (GN) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); As mentioned above, the final assembly of the bearings occurs in Mexico using cages and rollers from China. Since the subject bearings contain non-originating materials, they are not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is the product produced exclusively from originating materials per GN 11(b)(ii). We must therefore consider whether the merchandise qualifies as originating pursuant to GN 11(b)(iii). As noted above, the merchandise is classified in subheading 8482.20.00, HTSUS. The applicable product-specific rule of origin in GN 11(o)/8482.20 is underscored and requires: 246 (A) a change to subheadings 8482.10 through 8482.80 from any subheading outside that group, except from tariff items 8482.99.05, 8482.99.15 or 8482.99.25; The applicable subheading rule provides that “the underscoring of the designations in subdivision 246 pertain to goods provided for in subheadings 8482.10 through 8482.80 for use in a motor vehicle of chapter 87.” Furthermore, Chapter rule 7 for goods of Chapter 84 provides that “for the purposes of the subdivisions pertaining to this chapter, whenever the subdivision designation is underscored, the provisions of subdivision (k) of this note may apply to goods for use in a motor vehicle of chapter 87.” In recognizing the product-specific rule is underscored, and the merchandise is for use in a motor vehicle of chapter 87 (namely, a heavy-truck), the provisions of subdivision (k) may apply. GN 11(k)(ii)(E)(2) includes in the definition of an “automotive good” any “part, component or material listed in table A.1, A.2, B, C, D, or E of the automotive appendix, subject to any provisions that may be included in regulations issued by the Secretary of the Treasury.” GN 11(k)(ii)(D) defines the “automotive appendix” as “. . . the Appendix to Annex 4-B of the USMCA (relating to the product-specific rules of origin for automotive goods, as reflected in subdivision (o) of this note).” Examining Table E of the automotive appendix, titled “Complementary Parts for Heavy Trucks,” the subject merchandise is listed (8482.20 Tapered roller bearings, including cone and tapered roller assemblies) and is for use in heavy trucks. The Note to Table E in the automotive appendix provides that “the Regional Value Content requirements set out in Article 4 of this Appendix apply to a good for use in a heavy truck.” Notwithstanding the Product-Specific Rules of Origin in Annex 4-B, each Party shall provide that the regional value content requirement for a part listed in Table E of this Appendix that is for use in a heavy truck is: (L) Notwithstanding subdivision (o) of this note, the regional value content requirement for a part listed in Table E of the automotive appendix that is for use in a heavy truck is: (1) 50 percent under the net cost method or 60 percent under the transaction value method, if the corresponding rule in subdivision (o) includes a transaction value method, beginning on July 1, 2020; (2) 54 percent under the net cost method or 64 percent under the transaction value method, if the corresponding rule in subdivision (o) includes a transaction value method beginning on July 1, 2024; and (3) 60 percent under the net cost method or 70 percent under the transaction value method, if the corresponding rule in subdivision (o) includes a transaction value method, beginning on July 1, 2027, and thereafter. Article 4.3 of the automotive appendix correlates to GN 11(k)(iii)(L), and repeats the regional value content requirements for goods listed in Table E. In addition to the provisions of the automotive appendix and GN 11, as indicated in GN 11(a)(i), the trilaterally agreed USMCA Uniform Regulations in Appendix A of 19 CFR, Section 182 provides further guidance on the interpretation and application of the USMCA rules of origin. The Note to Table E in the Uniform Regulations clarifies that: The Regional Value Content requirements set out in Sections 13 or 15 or Schedule I (PSRO Annex) apply to a good for use as original equipment in the production of a heavy truck. For an aftermarket part, the applicable product-specific rule of origin set out in Section 13 or Schedule I (PSRO Annex) is the alternative that includes the phrase “for any other good.” Accordingly, the Uniform Regulations draw a distinction between aftermarket parts and automotive parts that are used as original equipment in the production of a vehicle. See Section 12(1), which states that the term aftermarket part means a good that is not for use as original equipment in the production of passenger vehicles, light trucks or heavy trucks as defined in these Regulations. Here, the TRBs will be used either as original equipment or as aftermarket parts. In accordance with the Note to Table E, when the merchandise is used as aftermarket parts, the applicable product-specific rule of origin is the rule in Section 13 or Schedule I (PSRO Annex) of the Uniform Regulations. Schedule I provides that “this schedule is deemed to be the contents of Sections A, B and C of Annex 4-B of the Agreement, as implemented in General Note 11 of the HTSUS.” Here, Section 13 of the Uniform Regulations does not contain a product-specific rule of origin for goods of 8482.20, HTSUS. Therefore, the rule applicable to the merchandise when used as aftermarket parts is contained in GN 11(o)/8482, rule (A) requires a change to subheadings 8482.10 through 8482.80 from any subheading outside that group, except from tariff items 8482.99.05, 8482.99.15 or 8482.99.25. You have provided information necessary to determine whether the tariff shift rule in GN 11(o)/8482.20, Rule A, has been satisfied. As noted above, this rule requires a change to subheadings 8482.10 through 8482.80 from any other subheading outside that group. Based on the information provided, the non-originating materials are classified in a subheading outside that group. As a result, provided that all other requirements are met, the TRBs will be eligible for preferential tariff treatment under the USMCA when used as aftermarket parts. In determining the rule of origin applicable to TRBs used as original equipment, as indicated above in GN 11(k)(iii)(L), the regional value content requirement for a part listed in Table E of the automotive appendix for use in a heavy truck is: 54 percent under the net cost method or 64 percent under the transaction value method, if the corresponding rule in subdivision (o) of this note includes a transaction value method, beginning on July 1, 2024; The applicable rule in GN 11(o)/8482 contains only a tariff shift rule; however, since the TRBs are for use as original equipment, they must meet the RVC requirements in GN 11(k)(iii)(L) in order to qualify for preferential tariff treatment under the USMCA. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division