OT:RR:NC:N1:102
Edward Hayes
Leake Andersson
1100 Poydras Street, Suite 1700
New Orleans, LA 70163
RE: The country of origin of bearings
Dear Mr. Hayes:
In your letter dated September 24, 2025, you requested a country of origin ruling on behalf of your client,
EBI Transmission System (Thailand) Co., Ltd. A description of the assembly processes was provided in the
submission.
The products at issue are a deep groove ball bearing, part number EBT1241, and a tapered roller bearing, part
number L44649. The ball bearing consists of outer and inner races that incorporate steel balls, a sealing ring
and a retainer. The ball bearing is used in motor vehicles to reduce friction and to support radial and axial
loads. The tapered roller bearing consists of a cup, which functions as the outer race, a cone, tapered rollers
and a retainer. The tapered roller bearing supports radial and unidirectional axial loads of wheel assemblies
used in motor vehicles.
With respect to origin, the final assembly of both types of bearings occurs in Thailand using components
sourced from China. Prior to the final assembly process of both bearings, rings sourced from China undergo
various processes in Thailand, in which the steel rings are transformed into races with precision raceways.
Such processes include rough machining, a heat treatment, and various phases of precision grinding, honing
and superfinishing processes. To form the ball bearing, a seal ring and balls are mounted into a retainer,
which is afterwards mounted into inner and outer races. The components are then hydraulically pressed
together, and lubrication is applied as needed. For the tapered roller bearing, rollers are mounted into a
retainer, which is subsequently mounted onto a cone. The cone assembly is then mounted into a cup, and the
components are hydraulically pressed together. Each finished bearing is subject 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 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).
In this instance, the final assembly processes that occur for both types of bearings would not entail the type of
processing required to meet the substantial transformation test. The assembly of the ball and tapered roller
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, steel rings are transformed into races with
precision raceways subsequent to the machining, precision grinding, honing and the superfinishing processes
that occur in Thailand. Therefore, as the country of origin of the inner and the outer races with precision
raceways is Thailand, the country of origin of the deep groove ball bearing and the tapered roller bearing is
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 Sandra Martinez at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division