OT:RR:NC:N2:206
Adams Lee
Harris Sliwoski LLP
600 Stewart Street ,Suite 1200
Seattle, WA 98101
RE: The country of origin of wheel hub units
Dear Mr. Lee:
In your letter dated September 24, 2025, you requested a country of origin ruling on wheel hub units, which
you filed on behalf of Botai Auto Parts (Thailand) Co., Ltd.
The products under consideration are double flanged wheel hub units, Part Number 515046, which
incorporates tapered roller bearings and Part Number 513296, which incorporates ball bearings. The wheel
hub units are used in passenger vehicles and light and heavy trucks. They have holes or bolts on the flange
end face which can be directly connected to the wheel rim of the motor vehicle to support and bear the
weight of the wheels as well as the load from the road surface. The wheel hub units provide stable axle
support through the inner and outer roller bearings, providing anti-friction functions, which allow for the
smooth rotation of the wheels. They connect to the vehicle’s drivetrain and transfer power generated by the
engine or electric motor to the wheels, enabling the vehicle to move. The subject hub units are equipped with
anti-lock braking system (ABS) sensors which enhance braking precision, performance, and safety. They
reduce friction between moving parts of a vehicle, thus helping to improve fuel efficiency, reduce noise, and
extend the life of other components.
The wheel hub units consist of inner and outer flanges, inner and outer rings, tapered rollers (515046) or ball
bearings (513296), retainers, seal rings, ring gear, cage, O-ring, dust cover, antilock braking system (ABS)
sensors, and bolts.
You state that steel bars are purchased from China and imported into Thailand. In Thailand, the steel bars are
cut to size, then forged into the inner and outer flange shapes. The rough forged flange shape then undergoes
multiple fine turning steps. The rough-finished flanges then undergo various finishing processes such as heat
treatment, machining, center-grinding and other processes. The outer flange then undergoes grinding to make
the super fine raceways.
The inner ring heat treated forging is imported from China into Thailand and processed by grinding outer
circles, grinding raceways, and grinding inner holes. After the super-fine raceways are grinded, the inner
rings are demagnetized and cleaned and assembled together with the rest of components, which are sourced
from China.
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 the present case, the steel bars are substantially transformed into the inner and outer flanges in Thailand.
Furthermore, the inner ring becomes a race with precision raceway in Thailand. This rationale is noted in
Headquarters (HQ) ruling 562528, dated December 10, 2002, which discusses the country of origin of a ball
bearing. This ruling 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 rulings 731968, dated 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.
The rest of the components from China that are incorporated into the wheel hub units, such as ring gear, dust
cover, rolling elements, seal rings, cages, bolts, ABS sensors, and grease are minor components. Therefore,
the country of origin of the double flanged wheel hub units, Part Number 515046, which incorporates tapered
roller bearings and Part Number 513296, which incorporates ball bearings, will be Thailand for marking
purposes and for purposes of applying trade remedies under Section 301 and additional duties.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division