The country of origin of a control arm and ball joint assembly

N349014 June 6, 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 control arm and ball joint assembly Dear Mr. Hou: In your letter dated May 14, 2025, you requested a country of origin ruling on a control arm and ball joint assembly. Pictures, videos, and other descriptive literature were provided with your request. The article under consideration is a control arm and ball joint assembly, Part No. TF-NA-CA-003, which is a component of a suspension system in passenger vehicles. It provides a smooth ride and creates stable road control, drivability and handling. The assembly weighs approximately 9 lbs. and it is made of steel with plastic and rubber components. The ball joint is integrated into the L-shaped control arm. The manufacturing process takes place in Thailand where the steel bars imported from China are forged into the raw ball stud and housing (socket) blanks. The raw ball stud is further processed using a high-precision CNC machine to shape the ball head and stud (cylindrical shank) of the ball stud. Then a pin hole is drilled at the bottom of the ball stud. Finally, a thread rolling (cold forming) operation is performed to enhance the strength, durability, and precision of the finished ball stud. Next, the housing blanks are further shaped by the high-precision CNC machine via precise turning of the housing blanks. Once the housing is complete, it is joined together with the ball stud to create the finished ball joint assembly. The control arm is also manufactured in Thailand using the raw steel imported from China. The raw steel is stamped in the shape of the control arm and further processed by punching and flanging of the control arm. After that, the ball joint assembly is press fitted into the control arm to create the finished control arm and ball joint assembly. The finished product is then packaged for shipment to the United States. 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 this case, the raw steel and steel bars imported from China undergo extensive machining, stamping, flanging, and other processes and become distinct components of the control arm and ball joint. These processes physically change the raw materials into an article with a new name, character, and use. As a result, it is the opinion of this office that the control arm and ball joint assembly are substantially transformed in Thailand. Therefore, the country of origin for the complete control arm and ball joint assembly, Part No. TF-NA-CA-003, 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, (for) Steven A. Mack Director National Commodity Specialist Division