RE: The country of origin of a tapered roller bearing wheel hub assembly

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364679 September 15, 2026 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 tapered roller bearing wheel hub assembly Dear Mr. Kenkel: In your letter dated August 27, 2026, you requested a country of origin ruling on a tapered roller bearing wheel hub assembly on behalf of Wan An (M) Sdn. Bhd. The article under consideration is a tapered roller bearing (TRB) wheel hub assembly, identified by the unique product numbers 25819667, WH151097, and A515097, which corresponds to the universal model number 515097, and is designed for use in passenger motor vehicles. The wheel hub assembly facilitates the rotation of the vehicle’s wheels and supports the vehicle while enabling smooth wheel movement. The assembly incorporates an anti-lock braking system (ABS) ring and is designed to reduce friction between moving components of the vehicle. The principal components of the wheel hub assembly include a spindle, outer ring, inner ring, tampered rollers, cages, sealing rings, ABS ring, sensor, and related components. The spindle, outer ring, and inner ring are manufactured from S55 steel in Malaysia. The remaining components, including the rollers, cages, sealing rings, sensor, and related components, are manufactured in China and imported into Malaysia for incorporation into the finished wheel hub assembly. In Malaysia, S55 steel is heated and subjected to a forging process to form rough blanks for the spindle, outer ring, and inner ring. The resulting forgings subsequently undergo finish turning using computer numerical control (CNC) machine tools to obtain the required dimensions and configuration. The components are then drilled as necessary and subjected to precision grinding operations to create the finished surfaces and bearing raceways. The raceway surfaces are subsequently honed and superfinished to achieve the required dimensional tolerances and surface characteristics. Following these manufacturing operations, the finished spindle, outer ring, and inner ring are assembled in Malaysia with the tapered rollers, cages, seals, ABS components, sensor, and other components. The assembly operations include installation and machining of the rollers and cages, pressing the components together, application of grease, installation of seals and other components, and roll-greasing of the completed unit. The wheel hub assembly is then subjected to ABS testing and final inspection before being laser marked, rust-proofed, 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 case, the spindle, outer ring, and inner ring begin in Malaysia as rough steel forgings that are not yet suitable for incorporation into the finished wheel hub assembly. Through finish turning, drilling, precision grinding, honing, and superfinishing in Malaysia, the rough forgings are manufactured into finished components possessing the dimensions, precision bearing surfaces, raceways, and functional characteristics necessary for use in the subject wheel hub assembly. These Malaysian-manufactured components are then combined with the remaining components and assembled, greased, tested, inspected, and finished in Malaysia to produce the completed tapered roller bearing wheel hub assembly. Based on the totality of the circumstances, we find that the manufacturing operations performed in Malaysia substantially transform the constituent materials and components into a new and distinct article of commerce. Accordingly, the country of origin of the tapered roller bearing wheel hub assembly, part numbers 25819667, WH151097, and A515097 corresponding with the universal model number 515097, is Malaysia. 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, (for) James P. Forkan Director National Commodity Specialist Division