OT:RR:NC:N:2:206
John Kenkel
International Trade Law Counselors, PLLC
8647 Richmond Hwy, Suite 623
Alexandria, VA 22309
RE: The country of origin of wheel hub units
Dear Mr. Kenkel:
In your letter dated January 14, 2026, you requested a country of origin ruling on wheel hub units on behalf
of Wan An (M) SDN. BHD.
The articles under consideration are non-splined wheel hub assemblies (units) containing tapered roller
bearings (TRBs), Models 515054, 515079, and 515084, which are used in passenger vehicles. Each unit
contains a hole or bolts on the spindle and outer ring, which can be directly connected to the wheel rim and
support the vehicle while enabling smooth rotation of the wheels. The spindle functions as a housing. Models
515054 and 515079 are equipped with anti-lock braking system (ABS) rings. These products 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.
You state that the outer rings, spindles and inner rings are imported from China in a rough
semi-manufactured state and precision machined in Malaysia. They undergo multiple precision turning
operations, drilling or tapping, grinding, and super-finishing, to create a finished product. Other components,
such as rollers, cages, sealing rings, senor, and senor rings are made in China and imported to Malaysia for
inspection and final assembly with Malaysian bolts. In Malaysia, the components are assembled together
using superfinishing machines, component optical matching machine, press machines, and a spin riveting
machine. After that, the wheel hub assemblies are inspected, laser marked, rust-proofed, tested, and packaged
for shipment.
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. Friedlaender & 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).
In the present case, the assembly of separate components does not result in a substantial transformation. Most
of the components comprising the wheel hub units are imported from China. Although you claim that the
spindles become housings and the inner rings become races with precision raceways in Malaysia, you
provided no evidence of it. The semi-manufactured components (the spindles and the rough races) of the hub
units from China undergo a minimal physical change. The processes that occur in Malaysia do not render
them a new name, character or use. The end-use of the components from China is predetermined before they
arrive in Malaysia for further processing and assembly, as the spindle and rough races are recognizable as a
hub and races with smooth bearing surfaces. Pursuant to the decision in the National Hand Tool Corp. v.
United States court case (16 CIT 308 (1992), aff’d, 989 F. 2d 1201 (Fed. Cir. 1993)), the Chinese
components do not substantially transform in Malaysia. As a result, it is the opinion of this office that the
country of origin of the non-splined wheel hub assemblies containing tapered roller bearings, Models
515054, 515079, and 515084, will be China for marking purposes.
In your letter, you also inquired about the country of origin of a wheel hub unit, Model 515040. Please note
that this article will be addressed in ruling N358371.
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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division