The country of origin of steel wheels

N348296 May 21, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Xiaozhen Qiao Joinhands Injection System (Thailand) Co., Ltd. 890 / 25 Moo 3 Khao Khan Song Subdistrict, Si Racha District, Chonburi Province 20110 Thailand RE: The country of origin of steel wheels Dear Ms. Qiao: In your letter dated April 26, 2025, you requested a country of origin ruling on steel wheels. The articles under consideration are steel wheels, PN A02101-01, which are used in automotive applications. They are mainly composed of two key components: the rim and the disc. The rim supports the tire and is in direct contact with it. Its shape and structural design must meet the requirements for the tire installation and use. The disc connects the rim to the hub, playing a role in supporting and transmitting force to ensure the overall stability and strength of the wheel. You state that the rim is manufactured in Thailand, while the disc is sourced from China to be assembled with the rim to create a complete steel wheel. The rim is produced using the roll-forming process. In this process, a steel plate is gradually bent into shape through multiple sets of rollers. After precise size control and shape adjustment, a rim is formed. This process ensures the accuracy and consistency of the rim, providing its strength and rigidity. The disc is mostly processed using the stamping process. Through one or more stamping operations, the disc structure is shaped to meet both mechanical performance and aesthetic requirements. The rim and disc are then joined together in a single unit through the welding process in Thailand. Additionally, to enhance the anti-corrosion performance and aesthetics of the steel wheels, they undergo a surface treatment process, which includes painting and electroplating. The painting process forms an anti-corrosion coating on the wheel surface through methods such as spraying or dipping, isolating the wheel from the external environment. The electroplating process deposits a layer of metal on the wheel surface, which not only improves the wheel's anti-corrosion ability but also gives it a unique appearance. 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 the present case, both main components, the rim and the disc, are integral components of the finished wheel. Taking into consideration the fact that final assembly involving significant processing occurs in Thailand and the value of the Thai components and additional labor amounts to approximately 89 percent of the total value, we find that a substantial transformation occurs in Thailand. Accordingly, the country of origin of the steel wheels 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