CLA-2-84:OT:RR:NC:N1:102
John Kenkel
International Trade Law Counselors, PLLC
8647 Richmond Highway, Suite 623
Alexandria, VA 22309
RE: The tariff classification and origin of a wheel hub unit
Dear Mr. Kenkel:
In your letter dated May 8, 2025, on behalf of Viet Nam Haiya Technology Co., Ltd., you requested a tariff
classification and country of origin determination ruling for the purpose of marking, Section 301 Trade
Remedies, and additional duties.
The article in question is referred to as a 2nd Generation wheel hub unit, item number F-616118-T. The
wheel hub unit is constructed of steel alloy and is used to support weight and reduce the radial and axial
friction as the tires rotate in passenger vehicles. The unit, which functions as an angular contact bearing, is
primarily comprised of an inner race, two rows of steel balls held in a cage, a seal constructed of rubber and
steel, and an outer flange that features mounting holes.
In your letter, you suggest the wheel hub unit is classified under 8708.99.8180, Harmonized Tariff Schedule
of the United States (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. We disagree, as the
wheel hub unit does not have any characteristics beyond that of an anti-friction ball bearing provided for
within heading 8482. Headquarters Ruling Letter 960049 dated August 26, 1997, explains that the flanged
outer rings are common to ball bearings and do not impart a significant non-friction reducing capability.
Furthermore, while the wheel hub unit may be designed to be incorporated into specific motor vehicles, it is
not legally relevant because many ball bearing types are manufactured to specific engineering and design
criteria and are purchased with a particular application in mind.
Accordingly, the applicable subheading for the 2nd Generation wheel hub unit, item number F-616118-T,
will be 8482.10.5016, HTSUS, which provides for Ball or roller bearings, and parts thereof: Ball Bearings:
Other: Angular contact bearings: Wheel hub bearing units: Flanged. The general rate of duty will be 9
percent ad valorem.
With respect to origin, you explain that the final assembly of the wheel hub unit occurs in Vietnam and
consists of components from China and Vietnam. Prior to the final assembly processes, the outer flange and
inner ring, which are sourced from China, undergo machining processes in Vietnam. The machining
processes consist of turning operations, drilling or tapping, grinding, and superfinishing processes, which
convert the rings into an inner race and an outer flange that functions as a race.
The final assembly, which occurs in Vietnam, begins by manually pressing Chinese sourced balls into cages
sourced from China. Afterwards, the caged balls are manually pressed into the outer flange. Next, an inner
race is pressed into the center bore of the outer flange and bolts are pressed into the outer flange. The
resulting assembly is machined pressed. Subsequently, grease from Vietnam is injected into the outer flange
and a seal is pressed onto the outer flange. Amongst these steps, the required gaskets and dust cover, which
are sourced from China, are installed. Once complete, the wheel hub unit is inspected, laser marked,
rust-proofed, tested and packaged for shipment.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling
Letter 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).
Additionally, 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.
In this instance, the final assembly processes that occur for the wheel hub unit are rather simple and do not
constitute a substantial transformation. Pressing components to each other is not considered to be complex.
The final assembly processes performed in Vietnam do not change the shape, character or predetermined use
of the inputs. Thus, like the ball bearings in Headquarters Ruling Letters 731968, dated March 19, 1990,
731969, dated March 19, 1990, and 562528, dated December 10, 2002, we look to the country in which the
rings become races with precision raceways to determine the origin, as they are the essential components of
anti-friction bearings. Here, the inner ring and the outer flange are transformed into races with precision
raceways in Vietnam. Accordingly, the country of origin of the wheel hub unit is Vietnam.
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
8482.10.5016, 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/.
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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division