The country of origin of sway bar links

N346637 April 2, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Victor Shengli VSolution Manufacturing (Thailand) Co., Ltd. 368/8 Moo.8, Map Kha, Nikhom Phatthana Rayong, 21180 Thailand RE: The country of origin of sway bar links Dear Mr. Shengli: In your letter, dated March 11, 2025, you requested a country of origin ruling on sway bar links. The items under consideration are two models of sway bar links, Type 1 (Part Number WD51205) and Type 2 (WD50820W), which are used in suspension systems of passenger vehicles. The two parts are similar and perform similar functions but vary in their ends. Sway bar links are essential components of a vehicle’s suspension system. When a car makes a sharp turn, the sway bar links help to maintain the balance of the car and improve its stability and handling. You state that steel bars are sourced from and forged into a ball pin and sway bar link body (a housing and rod blanks) in China. The forged products, along with steel scrap sheets for end caps from China, are imported into Thailand for further processing. In Thailand, the Chinese ball pin blank undergoes facing and rough turning, flat length and center hole drilling, rough finish turning, sphere turning, milling, threading, induction hardening (heat treatment), crack detection, coating, and polishing (burnishing). The forged sway bar link housing undergoes flat end face machine grooving, inner hole machining, riveting area machining, and final inspection. The forged rod undergoes rough machining, precision machining, and inspection. The housing and rod are then welded together, oiled, finish coated, laser marked and inspected. The scrapped steel is stretched, precision machined, thread tapped, heat treated, and surface treated (phosphate coating) to create an end cap. Finally, the finished components are assembled together with Thai-sourced bushing (for Type 2 model only), dust boot, and grease, and Chinese sourced clip ring and nut into a complete sway bar links. 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). Based on the information provided, the ball pin and sway bar link body forgings, as well as steel scraps for the end cap, undergo a major physical change and become functioning components of the sway bar links, when they are further processed in Thailand.?These processes are sufficiently complex and meaningful as to result in a substantial transformation, such that the Chinese components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. As a result, it is the opinion of this office that a substantial transformation occurs in Thailand. Therefore, the country of origin for the sway bar links, Type 1 (Part Number WD51205) and Type 2 (WD50820W) will be Thailand. 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