The country of origin of aluminum wheels

N349871 July 3, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Jane Taeger Progressive Trade Consulting 121 Chipola Road Cocoa Beach, FL 32931 RE: The country of origin of aluminum wheels Dear Ms. Taeger: In your letter dated June 5, 2025, you requested a country of origin ruling on aluminum wheels, which you filed on behalf of your client, Love’s Travel Stops & Country Stores. The articles under consideration are four models of aluminum wheels, FAW225X14M0 ALUM WHEEL MACH 0-OFFSET, Part Number 84U607; FAW225X14M2 ALUM WHEEL MACH 2IN OFFSET, Part Number 84U627; FAW225X825HM ALUM WHL MACHINED, Part Number 883977; and FAW245X825HM ALUM WHEEL MACH, Part Number 98U637. The aluminum wheels are used in semi-trailer trucks and trailers. The process of producing the aluminum wheels starts in China, where aluminum bars are cut, ingots undergo heating, forging into a circular shape, and expanding. You refer to this product as a “cookie.” After that, the “cookie” is exported to Thailand, where it undergoes flow forming (stretching the rim to the required size and structure), solution, turning, milling holes, drilling holes, finish turning, deburring, pre-cleaning, burnishing (sanding), polishing inside and outside, applying special coating on the surface of workpiece to prevent oxidation corrosion, removing polishing paste, loading valve, marking, testing, and packaging. In your letter, you reference Code of Federal Regulations (CFR), Title 19 Part 102 (Part 102 Rules), in your analysis. However, Part 102 Rules only pertain to goods from Mexico and Canada for marking purposes. None of the components in your scenario are made in Mexico or Canada, nor there are any processes done in those countries. As a result, Part 102 Rules do not apply. 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. In the instant case, the processes in Thailand do not transform the Chinese “cookie” into a new and different article, having a distinct name, character, or use. The product as imported from China has the shape and character of the wheel, and the use of the “cookie” is predetermined. As a result, this office finds that no substantial transformation occurs in Thailand, and the country of origin of the aluminum wheels is 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, James Forkan Acting Director National Commodity Specialist Division