The country of origin of a tie rod assembly

N344176 December 19, 2024 OT:RR:NC:N2:206 CATEGORY: Origin Victor Shengli VSolution Manufacturing (Thailand) Co., Ltd. 368/8 Moo.8, Map Kha, Nikhom PhatthanaRayong, 21180Thailand RE:  The country of origin of a tie rod assembly Dear Mr. Shengli: In your letter dated November 21, 2024, you requested a country of origin ruling on the tie rod assembly for marking purposes. In addition, you also requested an origin determination on the components of the tie rod assembly, such as the outer tie rod end and the inner tie rod end, if imported separately. The articles under consider consideration are a tie rod assembly (MFG Number VES3710A), and two components of the tie rod assembly, the outer tie rod end and inner tie rod end, which you may import separately. The tie rod assembly and its parts are essential components of a vehicle’s steering system as they ensure that the wheels are aligned enabling the vehicle to be steered accurately. The tie rods connect the steering gear to the steering knuckle on each front wheel. When the steering wheel is turned, the steering gear moves the tie rods, which in turn push or pull the wheels to change their direction. Additionally, the tie rods help maintain proper alignment of the wheels and help tires wear evenly. The tie rods connect directly to the steering gear through the inner tie rod and transfers the movement from the steering gear to the outer tier rod. The outer tie rod connects to the steering knuckle and transfers the movement from the inner tie rod to the wheel. The tie rod ends are the joints at the ends of the tie rods that allow for the necessary pivoting and movement. The inner tie rod is covered by a bellow kit or tie rod boot that protects it from dirt, debris, water, and other contaminants. 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. 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). The outer tie rod end is composed of a ball pin, housing, dust boot, end cap, grease, and bearing. The ball pin, steel bar for the housing forging blank, and scrap metal for the end cap are imported from China to Thailand for further processing and final assembly, with the Thai sourced dust boot, grease, and bearing, into the outer tie rod end. In Thailand, the ball pin forging undergoes facing and rough turning, center hole drilling, rod finish turning, sphere turning, pin hole drilling and machine milling, threading, induction hardening (heat treatment), crack detection, coating, and polishing. The housing forging blank undergoes rough machining, hole drilling and machining of the sphere, tapping the housing, induction hardening (heat treatment), surface treatment (phosphate coating), and laser marking. The scrap sheets of metal for the end cap are cut into blanks, undergo precision machining, thread tapping, heat treatment, and surface treatment (phosphate coating). All components are then inspected before assembly, the bearing is greased, the ball pin and bearing are fitted together and assembled with the housing, the product is riveted, greased in the groove, and the dust boot is installed. Surfaces are cleaned and the finished product is inspected. The inner tie rod end is composed of a socket, rod pin, grease, bearing, and nut. The socket and rod pin forgings are purchased in China, and imported to Thailand for further processing, and assembled with the Thai sourced grease, bearing, and nut. In Thailand, the socket forging undergoes facing, hole finishing and chamfering, hole drilling, threading, induction hardening, and finish coating. The rod pin forging undergoes heat treatment, shot blasting, crack detection, precision machining flat end facing and chamfering, (groove, turning neck, turning sphere), finish coating, threading, and final inspection. All components of the tie rod are then inspected, the bearing is greased, the rod pin and bearing are fit together, the product is assembled with the socket, riveted, greased in the groove, and the nut is installed. Surfaces are cleaned and the finished product is inspected. Finally, to create the complete tie rod assembly, the outer tie rod end and the inner tie rod end are combined with the Thai sourced bellow kit, and the finished product is inspected and packaged for import. Although assembling the components together is not complex enough to render a substantial transformation, there is a significant manufacturing that occurs in Thailand, which physically alters the Chinese forgings in such way that they become unrecognizable from their initial state as imported from China. After the processes in Thailand the forgings transform into identifiable and functional components of the outer and inner tie rod ends and the complete tie rod assembly. As a result, it is the opinion of this office that the outer and inner tie rod ends, and the complete tie rod assembly are substantially transformed in Thailand. Therefore, the country of origin of the outer and inner tie rod ends and the complete tie rod assembly is Thailand for marking purposes. 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 liana.alvarez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division