The country of origin of a steering tie rod

N347140 April 8, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Yicheng Hou Thaifu Automotive Co., Ltd. 19/33 Moo 5, Banbueng Banbueng 20170 Thailand RE: The country of origin of a steering tie rod Dear Mr. Hou: In your letter dated March 27, 2025, you requested a country of origin ruling on a steering tie rod. Pictures, videos, and other descriptive information was provided with your request. The item under consideration is a Steering Tie Rod (Part# TF-NA-TRE-001), which is used in passenger vehicles. It provides directional control of a car. The steering tie rod weighs approximately 2 pounds. It consists of a ball pin, steering rod, cotter pin, castle nut, dust cover, dust boot, plastic seat, and top cover. You state that the ball pin and steering rod forgings are made in China and shipped to Thailand for further processing. In Thailand, the forgings undergo precision drilling, machining, thread tapping, and tapping and milling with advanced CNC machines. The parts are then assembled with the rest of the components of Thai origin, by riveting and fitting components together. 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 National Hand Tool Corp., the court considered sockets and flex handles which were either cold formed or hot forged into their final shape prior to importation, speeder handles which were reshaped by a power press after importation, and the grip of flex handles which were knurled in the U.S. The court found that the drill bit blanks underwent no significant change in character or use when they were processed into the finished drill bits in China. In other words, the drill bit blanks had the very essence of the finished drill bits and the processing that was performed in China did not change the shape, character or predetermined use of the drill bits. Similarly in this case, the Chinese forgings do not undergo a significant change in Thailand. The machining, drilling, tapping, and milling, as well as the addition of Thai sourced rubber and plastic components, do not transform the character of the forgings into a new article with a new name, character, or use. As a result, no substantial transformation occurs in Thailand, and the country of origin of the Steering Tie Rod (Part# TF-NA-TRE-001), will be 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 liana.alvarez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division