The country of origin of a universal joint assembly

N347634 May 7, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Man je Kwak Onestop customs D-706-ho, 700, Pangyo-ro Bundang-gu, Seongnam-si 13516 Korea, South RE: The country of origin of a universal joint assembly Dear Mr. Kwak: In your letter dated April 10, 2025, you requested a country of origin ruling on a universal joint assembly for purposes of applying trade remedies, on behalf of your client, HL Mando Corporation. The article under consideration is a Universal Joint Assembly (NX4), which is used in steering systems of motor vehicles. It transmits the rotational force of the steering column to the steering gear. The rotational force of the steering wheel between the two axes (steering column and gear) is delivered smoothly and symmetrically by setting the appropriate phase angle and assembly angle resulting in the driver receiving a consistent sense of steering when turning the steering wheel. You state that the universal joint is also referred to as an intermediate shaft. The universal joint assembly is composed of a pinch bolt yoke from India, pipe yoke joint and shaft yoke joint from Vietnam, ball slip bush assembly, spider sub assembly, dust cap, and e-ring from South Korea, and needle bearing from China. The components are sent to Mexico for final assembly by stacking and fitting together the items. When determining the country of origin for purposes of applying current trade remedies, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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). The assembly in Mexico is not complex to render a substantial transformation. This office finds that the Vietnamese pipe yoke joint and shaft yoke joint are the dominant components that provide the character of the finished universal joint assembly. Furthermore, their value is significantly higher than the rest of the individual components. As a result, it is the opinion of this office that the country of origin of the universal joint assembly is Vietnam for purposes of applying trade remedies. Therefore, trade remedies under Section 301, as amended, from China will not apply. 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