OT:RR:NC:N:2:206

John Kenkel
International Trade Law Counselors, PLLC
8647 Richmond Hwy, Suite 623
Alexandria, VA 22309

RE: The country of origin of wheel hub units

Dear Mr. Kenkel:

In your letter dated January 14, 2026, you requested a country of origin ruling on wheel hub units on behalf of Wan An (M) SDN. BHD.

The articles under consideration are non-splined wheel hub assemblies (units) containing tapered roller bearings (TRBs), Models 515054, 515079, and 515084, which are used in passenger vehicles. Each unit contains a hole or bolts on the spindle and outer ring, which can be directly connected to the wheel rim and support the vehicle while enabling smooth rotation of the wheels. The spindle functions as a housing. Models 515054 and 515079 are equipped with anti-lock braking system (ABS) rings. These products reduce friction between moving parts of a vehicle, helping to improve fuel efficiency, reduce noise and extend the life of other components, ensuring optimal performance, safety, and comfort on the road.

You state that the outer rings, spindles and inner rings are imported from China in a rough semi-manufactured state and precision machined in Malaysia. They undergo multiple precision turning operations, drilling or tapping, grinding, and super-finishing, to create a finished product. Other components, such as rollers, cages, sealing rings, senor, and senor rings are made in China and imported to Malaysia for inspection and final assembly with Malaysian bolts. In Malaysia, the components are assembled together using superfinishing machines, component optical matching machine, press machines, and a spin riveting machine. After that, the wheel hub assemblies are inspected, laser marked, rust-proofed, tested, and packaged for shipment.

Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).

Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country-of-origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations.

A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).

In the present case, the assembly of separate components does not result in a substantial transformation. Most of the components comprising the wheel hub units are imported from China. Although you claim that the spindles become housings and the inner rings become races with precision raceways in Malaysia, you provided no evidence of it. The semi-manufactured components (the spindles and the rough races) of the hub units from China undergo a minimal physical change. The processes that occur in Malaysia do not render them a new name, character or use. The end-use of the components from China is predetermined before they arrive in Malaysia for further processing and assembly, as the spindle and rough races are recognizable as a hub and races with smooth bearing surfaces. Pursuant to the decision in the National Hand Tool Corp. v. United States court case (16 CIT 308 (1992), aff’d, 989 F. 2d 1201 (Fed. Cir. 1993)), the Chinese components do not substantially transform in Malaysia. As a result, it is the opinion of this office that the country of origin of the non-splined wheel hub assemblies containing tapered roller bearings, Models 515054, 515079, and 515084, will be China for marking purposes.

In your letter, you also inquired about the country of origin of a wheel hub unit, Model 515040. Please note that this article will be addressed in ruling N358371.

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 [email protected].
Sincerely,

(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division