The country of origin of a ball joint

N347758 May 8, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Roderick Bryant CTS Automotive Co LTD. 505 Gerald Bryant Rd Guntersville, AL 35976 RE: The country of origin of a ball joint Dear Mr. Bryant: In your letter dated April 14, 2025, you requested a country of origin ruling on a ball joint for marking purposes. The article under consideration is a Ball Joint (Part Number RBL-6241), which is a critical component in the suspension system of an automobile. It provides the necessary flexibility, support, and alignment to ensure a smooth and controlled driving experience. Additionally, the ball joint acts as pivot points for the steering system, allowing the wheels to turn left and right. The ball joint also supports the weight of the vehicle while allowing the suspension to move vertically. You state that the ball joint consists of the following components: a ball stud, dust cover, clamping 1 and 2, snap ring, bearing, protect cover, cover plate, nut, ball housing, and grease, which you source from China and import to Thailand for further processing. The ball stud and ball housing arrive to Thailand in a form of incomplete forgings, while the rest of the components arrive in their finished state. In Thailand, the ball stud forging undergoes tempering (heat treatment); machining process involving ball head rough turning, shank rough turning, undercut rough turning, ball head finish turning, shank finish turning, and undercut finish turning; and surface treatment, involving degreasing, water washing, pickling, water washing, activating the surface with an acidic activator, trivalent chromium plating, water washing, passivation, water washing, drying, inspection, and packaging. The ball housing forging undergoes tempering (heat treatment), machining: rough turning and fine turning of the housing, and surface treatment: E-coating, degreasing, water washing, hydrochloric acid, water washing, rust prevention, and electrophoresis in Thailand. Finally, the finished ball stud and ball housing are assembled together with the rest of the Chinese components in Thailand to produce a 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). In the present case, the main components of the ball joint, the Chinese ball stud and ball housing, are not clearly recognizable as parts until after the processes in Thailand. They undergo significant machining in addition to heat treatment that completely alters their physical state. As a result, it is the opinion of this office that the ball joint is substantially transformed in Thailand. Therefore, the country of origin for the ball joint (Part Number RBL-6241) 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