RE: The country of origin of wheel hub units

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363919 August 24, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Chandri Navarro Baker and McKenzie LLP 815 Connecticut Ave NW Washington, DC 20006 RE: The country of origin of wheel hub units Dear Ms. Navarro: In your letter dated July 31, 2026, you requested a country of origin ruling on wheel hub units, which you filed on behalf of Motorcar Parts of America, Inc. The articles under consideration are wheel hub units incorporating either ball bearings or tapered roller bearings. Parts WH515096, DLG515096, and A515096 incorporate splined inner flanges. The spline feature allows the hub to mesh with the drive axle and transmit torque. Part WH515054 is a non-splined unit, where the bearing/hub assemblies do not contain internal splined teeth that engage a drive axle to transmit torque. Each wheel hub unit mainly consists of an inner flange, outer flange, inner rings, cage, tapered rollers (or balls), anti-lock braking system (ABS) sensor, screws, tooth ring, shim, seals, and bolts of Chinese origin. The inner rings, outer flange, and inner flange are sourced from China in a raw, unfinished form and sent to Malaysia for further processing. The remaining components are not subject to any further processes in Malaysia and will be incorporated into the wheel hub units in the condition as imported. In Malaysia, the inner rings undergo grinding, superfine grinding, and auto-matching. The flanges undergo computer numerical control (CNC) lathe machining, bolt installation, grease application, seal installation, bearing set pressing, roll form (riveting), crack testing, examination, cap pressing, retainer installation, ABS sensor installation, internal End of Line (EOL) testing, voltage testing, spline broaching (for Parts WH515056, DLG515096, and A515096), anti-rust application, laser etching, and durability testing. Finally, the products are packaged and labeled ready for shipment. When determining the country of origin, 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).
In the instant case, the flanges and rings from China are dedicated for use in the finished wheel hub unit. Thus, the components have a pre-determined use at the time of exportation from China. In National Hand Tool, the Court of International Trade determined the country of origin marking requirements for imported individual tools which were used to produce flex sockets, speeder handles and flex handles. The court found that the character of the tools remained unchanged after heat-treatment, electroplating and assembly, and the form of the components remained the same since each component was either hot-forged or cold-forged into its final shape in Taiwan. Regarding Parts WH515096, DLG515096, and A515096, unlike the tools in the National Hand Tool that were in the final form at the time they left Taiwan and were clearly recognizable by name, the flanges in the said wheel hubs that leave China are not clearly recognizable as torque transmitting components. As the court stated in National Hand Tool, we must look at the totality of the evidence. The analysis must also consider the product at issue, how it functions, and the purpose of the components within it carrying out its function. The splining operation performed in Malaysia to the inner flange imparts a functionality beyond that of a mere hub. Rather, they become torque transmitting components that mesh (mate) with the axle to move the vehicle. Regarding Part WH515054, the outer flange and inner ring become races with precision raceways in Malaysia. Pursuant to decisions in Headquarters Ruling Letters 731968, dated March 19, 1990, 731969, dated March 19, 1990, and 562528, dated December 10, 2002, a bearing undergoes substantial transformation in the country where rings become races with precision raceways. Although the wheel hub assemblies in the instant scenario are not mere bearings, their function is to reduce friction and to allow the wheel to be mounted on the axle. Since the bearing rings are machined in Malaysia to form the precision raceways and subsequently assembled into the wheel hub units, we find that the components undergo a substantial transformation in Malaysia. Therefore, the totality of the evidence leads our office to conclude that the country of origin of Parts WH515096, DLG515096, A515096, and WH515054 is Malaysia. 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) James P. Forkan Director National Commodity Specialist Division