OT:RR:NC:N2:206
Didie Muller
Trade Pacific PLLC
700 Pennsylvania Ave SE
Washington, DC 20003
RE: The country of origin of a double flanged wheel hub unit with ball bearings
Dear Ms. Muller:
In your letter dated February 28, 2025, you requested a country of origin ruling on a double flanged wheel
hub unit incorporating ball bearings, which you filed on behalf of your client, Sihe Machine (Thailand) Co.,
Ltd.
The article under consideration is a double flanged wheel hub unit incorporating ball bearings, Part 513188,
which is used in passenger vehicles. The assembly features an outer flange and an inner flange, which work
together to support the wheel and axle connection. The outer flange is typically bolted to the wheel,
providing a secure mounting point, while the inner flange connects to the axle, via a splined interface for
torque transmission. Between the flanges, the rotating body, which includes the ball bearings, allows for
low-friction rotation of the wheel. The assembly also integrates an anti-lock braking system ABS sensor,
which monitors wheel speed for anti-lock braking functionality.
The outer and inner flanges are made in Thailand, while the rest of the components are made in China and
imported into Thailand for final assembly. In Thailand, the outer flange is made from a metal rod and
undergoes cutting, forging, normalizing, rough machining, shot blasting, turning, heat treating, turning again,
drilling, milling, grinding the surface and outer diameter, grinding raceway, and superfine grinding. The inner
flange is made from a metal rod and undergoes cutting, hot forging, normalizing, rough machining, shot
blasting, turning, heat treatment, turning again, drilling, splining, grinding raceway, and superfine grinding.
Next, the Chinese bolts are pressed into the inner flange, balls are installed into the outer flange, grease is
added, all components are combined together, and ABS sensor is installed. Finally, the product is cold
formed, laser marked, sprayed with anti-rust oil, and packaged for shipment to the United States.
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).
HQ ruling 562528, dated December 10, 2002, which discusses the country of origin of a ball bearing, states
that the fundamental character and use of the bearings is determined after the steel rings are ground and
finished into races with precision raceways and they are no longer considered steel rings. This rationale is
also discussed in HQ rulings 731968, dated March 19, 1990, and 731969, dated March 19, 1990, where rings
are heat treated and polished in one country and the races are created, and superfinishing occurs in the second
country. In these rulings, the country of origin of the bearings was determined to be the country in which the
rings become races with precision raceways.
In the instant case, however, the splining feature gives the wheel hub a functionality beyond a mere bearing.
It allows the wheel hub to mesh with the drive axle to transmit torque. As such, we find the outer and inner
flanges are the dominant components that impart the character of the double flanged wheel hub at issue.
Therefore, the country of origin of the double flanged wheel hub unit incorporating ball bearings, Part
513188, 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 Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division