The country of origin of ball joints

N345286 February 12, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Victor Shengli VSolutions Manufacturing (Thailand) Co., Ltd. 388/8 Mo.8, Map Kha, Nikhom Phatthana ,Rayong 21180Thailand RE:  The country of origin of ball joints Dear Mr. Shengli: In your letter dated January 21, 2025, you requested a country of origin ruling on  ball joints. The subject merchandise are Model 1 (Part Number YQ0051) and Model 2 (Part Number XQ10558) ball joints, which are designed to be used in passenger vehicle suspension systems. The ball joints are slightly different in their shape to fit different vehicle types. Model 1 contains a cylindrical housing, while Model 2 contains a flanged housing and a special nut. However, they follow the same production steps. Ball joints are a critical component in the suspension system of an automobile. They provide the necessary flexibility, support, and alignment to ensure a smooth and controlled driving experience. Additionally, ball joints act as pivot points for the steering system, allowing the wheels to turn left and right. Ball joints also support the weight of the vehicle while allowing the suspension to move vertically. According to the information supplied with your request, the ball joints consist of a ball pin, housing, dust boot, end cap, snap ring, clip ring, grease, bearing, and nut. The ball pin blank and cylindrical/flanged housing blank are forged in China from steel bars, and imported to Thailand for further processing. In Thailand, the ball pin forging undergoes flat head end face and rough turning, flat length and lead center hole drilling, rod finish turning, head rough turning, pin hole drilling and milling, thread rolling, induction hardening, crack detection, finish coating, and polishing. Similarly, in Thailand the cylindrical housing forging undergoes flat face and turning, flat length and lead center hole drilling, rough inner hole drilling, finish turning, knurling, induction hardening, and surface treatment. The flanged housing forging undergoes rough and precise machining on the big hole and small holes, heat treatment, finish coating, and screw tapping. The end cap is made in Thailand from left over steel sheet scraps from China by stretching, forming, punching, finish coating, and laser marking. The finished ball pin, housing, and end cap are then combined together with the Thai sourced dust boot, grease, and bearing, and the Chinese sourced snap ring, clip ring, and nut (including the special nut for Model 2) to form the finished ball joint. 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). Based on the facts presented, the ball pin forging, housing forging, and steel sheet scraps for the end cap undergo a major physical change and become functioning components of the ball joint, when they are further processed in Thailand. As a result, it is the opinion of this office that a substantial transformation occurs in Thailand. Therefore, the country of origin for the Model 1 (Part Number YQ0051) and Model 2 (Part Number XQ10558) ball joints will be 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