RE: The country of origin of wheel hub bearing assemblies

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 N364562 September 2, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Ms. Eunyoung Shim Shinhan Customs Service 704, Nonhyeon-ro Seoul 06052 South Korea RE: The country of origin of wheel hub bearing assemblies Dear Ms. Shim: In your letter dated August 25, 2026, you requested a country of origin ruling on wheel hub bearing assemblies on behalf of Iljin Global Co., Ltd. The merchandise under consideration consists of wheel hub bearing assemblies, identified as Part Numbers IJ123161, IJ113067, IJ123124, IJ223089, and IJ223153. The assemblies are designed for use in motor vehicles and function as the interface between the rotating and non-rotating components of the vehicle’s suspension system. The principal components include a hub, outer ring, inner ring, rollers, cage, seals, hub bolt, and grease. The submission proposes two manufacturing scenarios. Scenario 1 Under Scenario 1, the hub, outer ring, and inner ring are manufactured in China from steel round bar. In China, the hub outer ring undergoes cutting, forging, rough turning, heat treatment, finish turning, drilling, and tapping, as applicable. The inner ring similarly undergoes forging, turning, and heat treatment. At the time these components are exported from China, they have been formed into dedicated hub and bearing-ring components but have not yet undergone precision grinding or super-finishing. The remaining components, including the rollers, cage, open seal, pack seal, encoder seal, hub bolt, and grease, are also of Chinese origin. In South Korea, the hub outer ring, and inner ring undergo precision grinding to form the raceways and achieve the required dimensional tolerances, followed by super-finishing to obtain the required roundness and surface roughness. The components are then washed and inspected. Final assembly also occurs in South Korea. The assembly operations include pressing the hub bolt into the hub, assembling the roller and cage components, machining and pressing the inner ring, orbital forming, installing the outboard seal, performing ABS output inspection, and conducting precision clearance matching. The completed assemblies are subsequently inspected, packaged, and shipped.
Scenario 2 The processing of the hub, outer ring, and inner ring under Scenario 2 is substantially the same as the processing described in Scenario 1. These components are manufactured in China through forging, turning, heat treatment, and other machining operations before being exported to South Korea as semi-finished hub and bearing-ring components. In South Korea, the hub, outer ring, and inner ring undergo precision grinding and super-finishing, followed by washing, inspection, and final assembly. Unlike Scenario 1, the rollers, cage, open seal, pack seal, encoder seal, hub bolt, and grease used in Scenario 2 are manufactured in South Korea or purchased as South Korean-origin components. The final wheel hub bearing assembly is completed and inspected in South Korea. 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). We have considered NY N340514, dated July 3, 2024, and HQ 562528, dated December 10, 2002, which you cite in your request. While those decisions recognize the significance that precision grinding, super-finishing, and related operations may have in determining the origin of bearing components, substantial transformation determinations are necessarily fact specific. In the present case, the extent of the Chinese manufacturing, together with the condition, dedication configuration, and predetermined use of the hub, outer ring, and inner ring upon exportation from China, more closely resembles the circumstances considered in NY N357817, dated February 12, 2025. NY N357817 had U.S. Customs and Border Protection (CBP) consider the country of origin of wheel bearing components that were manufactured in China and subsequently subjected to precision processing and assembly outside China. CBP determined that the subsequent precision honing, drilling, tapping, grinding, and finishing operations did not substantially transform the Chinese components because their essential character and ultimate use as bearing components had already been established before they left China. In the case currently under consideration, the hub, outer ring, and inner ring undergo significant manufacturing operations in China. Steel round bars are cut, forged, turned, heat-treated, drilled, tapped, and otherwise machined into identifiable components having dimensions and physical configurations dedicated to their ultimate use in a wheel hub bearing assembly. Although the components require additional precision processing before they are suitable for incorporation into the finished assembly, their identity and predetermined use as bearing components have already been established when they leave China. We re cognize that the precision grinding and super-finishing operations performed in Korea are technically significant. However, the fact that additional precision machining is necessary to render a component suitable for its ultimate application does not, by itself, establish that a substantial transformation has occurred. In both proposed scenarios, the hub, outer ring, and inner ring, which constitute the principal structural and functional components of the wheel hub hearing assembly, are manufactured in China into identifiable components with a dedicated end use. Although these components undergo precision processing and are assembled in Korea, those operations do not substantially transform the Chinese-origin components into new and different articles of commerce. The use of Korean-origin rollers, cages, hub bolts, grease, and other components in Scenario 2 does not alter this determination. Accordingly, the country of origin of the wheel hub bearing assemblies under both scenarios is China. 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