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 country of origin of wheel bearings
Dear Mr. Kenkel:
In your letter dated August 4, 2025, you requested a tariff classification and country of origin determination
ruling of behalf of your client, Pearl Machine (Thailand) Co., Ltd.
The products at issue are wheel bearings, identified by model numbers 510070 and 510089. The steel
bearings, which are designed to support axial and radial loads, consist of an outer ring, inner rings, and a
double row of balls incorporated into cages. The bearings are used in wheel hub assemblies installed in
sedans, sports utility vehicles, crossover utility vehicles, minivans and light trucks.
The applicable subheading for the wheel bearings will be 8482.10.5028, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Ball or roller bearings, and parts thereof: Ball bearings: Other:
Angular contact bearings: Other. The general rate of duty will be 9 percent ad valorem.
With respect to origin, the final assembly of the wheel bearings occurs in Thailand using components sourced
from Thailand and China. Prior to the final assembly process, rings sourced from China undergo various
processes in Thailand, in which the rings are transformed into races with precision raceways. Such processes
include turning (rough and finishing), a heat treatment, grinding, and honing or rapping. Afterwards, balls
from China are inserted into cages from China, which are then positioned within two inner races and an outer
race. Then, pre-lubricated seals are installed, and the components are secured in place using a press machine.
Once complete, the bearing is subjected to an anti-rust treatment and is laser marked.
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 (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).
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 in Thailand would not entail the type of processing
required to meet the substantial transformation test. The assembly of the ball bearing is rather simple.
Inserting and pressing components does not substantially transform the Chinese components. Instead, we
look to the country of origin of the inner and outer races, which CBP has concluded are the essence of
anti-friction bearings. See HQ Ruling Letters 562528, dated December 10, 2002, 731968, dated March 19,
1990, and 731969, dated March 19, 1990. Here, the origin of the inner and the outer races with precision
raceways is Thailand. Accordingly, the country of origin of the wheel bearings will be Thailand for the
purpose of marking and current trade remedies.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e., 9903.81.91, in addition to subheading 8482.10.5028, HTSUS. Derivative iron or
steel products processed in another country from steel articles melted and poured in the United States,
provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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 of Thailand will be
subject to an additional ad valorem rate of duty of 19 percent. For products covered by heading 9903.81.91
this additional duty applies to the non-steel content of the merchandise. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e., 9903.02.61, in addition to subheading
8482.10.5028, 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division