CLA-2-87:OT:RR:NC:N2:206
John Kenkel
International Trade Law Counselors, PLLC
8647 Richmond Hwy, Suite 623
Alexandria, VA 22309
RE: The tariff classification and country of origin of wheel hub assemblies
Dear Mr. Kenkel:
In your letter dated May 8, 2025, you requested a tariff classification and country of origin determination
ruling, which you filed on behalf of your client, Viet Nam Haiya Technology Co., Ltd.
The items under consideration are 2nd Generation wheel hub assemblies containing ball or tapered roller
bearings (Model Number F-616113-S and Model Number J-616046-S, respectively). The wheel hub
assemblies are used in passenger vehicles. There are holes or bolts on the flange end face, which can be
directly connected to the wheel rim and support the weight of the vehicle while enabling smooth rotation of
the wheels. The assemblies are equipped with anti-lock braking system (ABS) rings. They are often
integrated with ABS sensors in modern vehicles, which enhance braking precision and safety. The wheel hub
assemblies 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.
The assemblies consist of an outer flange, inner rings, balls or rollers, cages, magnetic ring (ABS ring), and a
seal ring. You state that the outer flanges and inner rings are imported from China and machined in Vietnam.
The flanges are imported from China in an unfinished state and then fully processed by multiple precision
turning operations, drilling or tapping, grinding, and super-finishing, to create a finished product. The inner
rings also are fully processed from an unfinished state through multiple grinding, super-finishing, and other
manufacturing processes to produce the precision raceways. The balls, rollers, cages, seals, and ABS rings
are all made in China and imported to Vietnam for inspection and final assembly. In Vietnam, the
components are assembled together using ball automatic assembly machines and hydraulic presses. After
that, the wheel hub assemblies are inspected, laser marked, rust-proofed, tested, and packaged for shipment.
The applicable subheading for the 2nd Generation wheel hub assemblies, containing ball bearings (Model
Number F-616113-S) and tapered roller bearings (Model Number J-616046-S) will be 8708.99.8180,
HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other
parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent
ad valorem.
Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile
parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05,
as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading
8708.99.8180, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
8708.99.8180, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided
for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying
duty rates are provided at https://hts.usitc.gov/.
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. Friedlander & 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).
The final assembly of the Chinese components in the present case does not appear to be complex; however,
the outer flange and inner ring become races with precision raceways in Vietnam. Pursuant to decisions in
Headquarters Ruling Letters 731968, dated March 19, 1990, 731969, dated March 19, 1990, and 562528,
dated December 10, 2002, a bearing undergoes substantial transformation in the country where rings become
races with precision raceways. Although the wheel hub assemblies in the instant scenario are not mere
bearings, their function is to reduce friction and to allow the wheel to be mounted on the axle. Since the outer
flange and inner ring become races with precision raceways in Vietnam and drilling of the bolt holes also
occurs in Vietnam, the country of origin of the wheel hub assemblies (Model Number F-616113-S and Model
Number J-616046-S) will also be Vietnam for marking purposes.
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)
Steven A. Mack
Director
National Commodity Specialist Division