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 roller bearings
Dear Ms. Muller:
In your letter dated March 19, 2025, you requested a country of origin ruling on a double flanged wheel hub
unit incorporating tapered roller bearings, on behalf of your client, Hubble Autoparts Manufacturing
(Thailand) Co., Ltd.
The article under consideration is the Double Flanged Wheel Hub Unit with Tapered Roller Bearings, Item
number 515170, 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 and supporting axial and rail loads, while the inner flange
connects to the axle. The assembly includes housed tapered roller bearings between the flanges which allows
for low-friction rotation of the wheel and 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 (i.e., cage, tapered rollers,
seal ring, dust cover, ring gear, bolt, ABS sensor, and inner ring) are made in China and imported into
Thailand for final assembly. In Thailand, the outer flange is made from a metal rod that undergoes cutting,
hot forging, normalizing, shot blasting, turning 1, heat treatment, turning 2 and 3, drilling, outer diameter
grinding, raceway grinding, and superfine grinding. The inner flange is made from a metal rod and
undergoes cutting, hot forging, normalizing, shot blasting, turning 1, heat treatment, drilling, and turning 2
and 3. The wheel bearing unit assembly process includes installing rolling elements, pressing the ring gear,
fitting bolts, installing the seal ring, performing clearance detection, applying grease, assembling
components, conducting another clearance check, cold forming, crack detection, vibration testing, installing
seal ring, installing and measuring the ABS sensor, laser marking, applying anti-rust oil, and
packaging/packing according to customer specifications before being shipped 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).
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HQ 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 are 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 731968, dated March 19, 1990, and HQ 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.
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The imported Chinese components are assembled together with the inner and outer flanges in Thailand by
means of pressing, installing, and otherwise assembling. Such operations do not substantially transform the
Chinese components in Thailand. As a result, we must determine which component imparts the identity of
the wheel hub unit. In New York Ruling Letter (?NY?) N336938, dated December 27, 2023, we stated that a
wheel hub unit enables the wheels to be installed on to the axle and provides anti-friction. Therefore, we
determined that the character of the wheel hub unit is the combination of the flanges and the inner race. In the
instant case, the flanges are of Thai origin, while the race is of Chinese origin. Due to the fact that the final
assembly occurs in Thailand, and the value of the Thai components amounts to approximately 69.2 percent of
the total cost, it is the opinion of this office that the country of origin for the double flanged wheel hub unit
incorporating tapered roller bearings will be Thailand.
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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.
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This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
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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