The tariff classification and country of origin of loaded knuckle assemblies

N351996 August 20, 2025 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification; Origin TARIFF NO.: 8708.80.6590; 9903.94.05; 9903.01.33 John Kenkel International Trade Law Counselors, PLLC 8647 Richmond Hwy, Suite 623 Alexandria, VA 22309 RE: The tariff classification and country of origin of loaded knuckle assemblies Dear Mr. Kenkel: In your letter dated August 4, 2025, you requested a tariff classification and country of origin determination ruling, which you filed on behalf Pearl Machine (Thailand) Co, Ltd. The articles under consideration are loaded knuckle assemblies, Models LK410 and LK416, which are used in passenger vehicles. Each assembly consists with a steering knuckle integrated with additional components, including a wheel bearing, spindle, and fender, forming a complete sub-assembly. The assemblies include knuckle, outer ring, spindle, fender, inner ring, steel ball, cage, snaping ring and seal ring. The final assembly process involves pressing the wheel bearing, spindle, and fender into the machined steering knuckle using specialized equipment. These products reduce friction between moving parts of a vehicle, helping to improve fuel efficiency, reduce noise and extend the life of other components, ensuring optimal performance, safety, and comfort on the road. You state that the knuckles, outer rings, spindles, and bolts are produced from the casting stage/forging stage in Thailand, while the inner rings (in a rough, semi-manufactured state) are imported from China. The inner rings are precision machined in Thailand by precision turning operations, drilling or tapping, grinding, and super-finishing, to create a finished product. After the above procedures, a complete precision raceway is produced. Other minor accessories such as the fender, cages, sealing rings, steel balls, snaping rings are all made in China and imported into Thailand for inspection and final assembly. In Thailand, the components are assembled together using superfinishing machines, component optical matching machine, press machines, and a spin riveting machine. After that, the loaded knuckle assemblies are inspected and packaged for shipment. The applicable subheading for the Loaded Knuckle Assemblies, Models LK410 and LK416, will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading 8708.80.6590, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Thailand will be subject to an additional ad valorem rate of duty of 19 percent. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.33, in addition to subheading 8708.80.6590, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. 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 major components of the knuckle assembly, such as the knuckle, outer rings, and spindles undergo substantial transformation in Thailand when they become identifiable components after the forging process. Furthermore, HQ ruling 562528, dated December 10, 2002, which discusses the country of origin of a ball bearing, states that the fundamental character and use of the bearings is determined after the steel rings are ground and finished into races with precision raceways and they are no longer considered steel rings. See also HQ rulings 731968, dated March 19, 1990, and 731969, dated March 19, 1990. Similarly in this case, the inner rings from China became races with precision raceways in Thailand. As a result, the country of origin of the Loaded Knuckle Assemblies, Models LK410 and LK416, 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, (for) James Forkan Acting Director National Commodity Specialist Division