OT:RR:NC:N2:206
Edward Hayes
Leake Andersson
1100 Poydras Street, Suite 1700
New Orleans, LA 70163
RE: The country of origin of wheel hub units
Dear Mr. Hayes:
In your letter dated May 1, 2025, you requested a country of origin ruling on wheel hub units, which you
filed on behalf of your client, EBI Transmission System (Thailand), Co., Ltd.
The articles under consideration are double flanged wheel hubs with ball bearings (EBH3160 - MOOG:
513308, EBH3182 - MOOG: 513258) and double flanged wheel hubs without ball bearings (EBH1572 - OE:
7T4Z1104A, and EBH1534 - OE: 42210-S0H000), which are designed to be used in passenger vehicles, and
light and heavy trucks. They are also referred to as wheel hub bearings, wheel bearings, or axle bearings. The
wheel hubs are installed on the axle of the motor vehicle to support and bear the weight of the wheels as well
as the load from the road surface. They provide stable axle support through inner and outer bearings,
providing anti-friction functions which allow the wheels to rotate smoothly. They also transmit power
generated by the engine or electric motor to the wheels, enabling the vehicle to move. In addition, the wheel
hubs are combined with the vehicle's suspension system to provide suspension support, alleviate vibrations,
and any impacts caused by uneven road surfaces, to provide better ride comfort and stability.
The wheel hub units with ball bearings consist of inner rings, inner and outer flanges, rollers, retainers, seals,
anti-lock braking system (ABS) sensor, and bolts. The wheel hub units without ball bearings contain the
same components, but do not incorporate an outer ring or any roller elements. The main material used is
high-carbon chromium steel (such as GCr15) to ensure the wheel hubs are wear and fatigue resistant.
You state that steel round rods (bars) for inner/outer flanges and inner rings, as well as the bolts, steel balls
(when applicable), sealing rings, ABS sensors, gear rings, gaskets, retainers, dust covers, and grease are
imported from China to Thailand for further processing. In Thailand, the steel rods undergo cutting into
billets, forging, vortex heating, preforming into an outer flange, inner flange, and inner ring, rough
machining, heat treatment, drilling, grinding, super-fining, ultrasonic cleaning, and spin riveting.
The outer flange then undergoes fine two and fine three grinding, drilling, chamfering, tapping, deburring,
outer circle and channel grinding, demagnetizing, and cleaning. The inner flange undergoes fine two and fine
three grinding, drilling, chamfering, tapping, splining, channel grinding, and demagnetizing. The inner ring
undergoes channel grinding, inner grinding, superfine channel grinding, demagnetizing, and cleaning.
The inner/outer flanges and inner rings are then assembled with the rest of the Chinese components in
Thailand by pressing and fitting items into each other to create complete wheel hub units.
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, 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 hubs at issue.
Since the Chinese rods (bars) are made into flanges and rings in Thailand, and the splining is machined in
Thailand, we find that a substantial transformation occurs in Thailand. Therefore, the country of origin of the
double flanged wheel hub units with ball bearings (EBH3160 - MOOG: 513308, EBH3182 - MOOG:
513258), and wheel hub units without bearings (EBH1572 - OE: 7T4Z1104A, and EBH1534 - OE:
42210-S0H000) 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