The tariff classification and country of origin of ball joints and pitman arms

N352712 September 12, 2025 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification; Origin TARIFF NO.: 8708.80.6590; 8708.94.7550; 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 ball joints and pitman arms Dear Mr. Kenkel: In your letter dated August 20, 2025, you requested a tariff classification and country of origin determination ruling, which you filed on behalf of your client, GAA Malaysia Automotive Technology Sdn Bhd. The articles under consideration are Ball Joints, Model Numbers X-00024J, X-0241J and X-00039J, and Pitman Arms, Model Numbers BT-7087J-42CrMo and BT-7142J, which are used in passenger vehicles. You state that Model X-00024J and X-0241J are ball head assemblies, while model X-00039J is single ball joint. The ball joints are assembled on the suspension arm, and the ball pin is installed on the horn, which controls the freedom of the tire and ensures that the car runs within a controllable range. The functions of the ball joints are to reduce the impact caused by large obstacles such as speed bumps, ensure the comfort of the vehicle, and provide necessary support for the vehicle body. The pitman arms are components that cooperate with the steering gear to make the steering tie rod operate in parallel. They ensure that the left and right front wheels can turn at a predetermined angle. As part of the vehicle group's steering system, the main function of the pitman arms is to ensure the stability and accuracy of the steering system, enabling drivers to experience a smooth and precise turn. The ball joints contain sub-assemblies including a boot, ball pin, ball socket, backing plate, housing and other associated accessories. The boot, housing, and ball pin are sourced from Malaysia. Other components such as the nut, bolt, glib, gasket, spiral and ball socket are imported from China. These imported components are then subject to multiple precision turning operations, riveting, greasing, and press-fitting in Malaysia to create a finished product. In Malaysia, the components are assembled together using computer numerical control (CNC) machine, pressing machine, riveting machine, molding machine, grease pump machine, automatic clip machine, hardness taster. After that, the ball joints are inspected, laser marked, tested, and packaged for shipment. The pitman arms contain sub-assemblies including a boot, ball pin, ball socket, backing plate, housing and other associated accessories. Similarly, the boot, housing and ball are sourced from Malaysia. Other components, such as the nut, bolt, glib, gasket and ball socket are imported from China. These imported components are then subject to precision turning, riveting, greasing, pressing, and other finishing operations in Malaysia before final assembly. In Malaysia, the completed Pitman arms are then assembled using the same set of specialized machinery as with the ball joints, followed by inspection, laser marking, testing, and packaging. The applicable subheading for the Ball Joints, Model Numbers X-00024J, X-0241J and X-00039J, will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of heading 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. You suggest that the pitman arms also be classified in subheading 8708.80, HTSUS, as parts of suspension systems. Although they interact with the suspension systems, the pitman arms are components of steering systems. As a result, they are more specifically provided for in subheading 8708.94, HTSUS, as parts of steering systems. The applicable subheading for the Pitman Arms, Model Numbers BT-7087J-42CrMo and BT-7142J, will be 8708.94.7550, HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Steering wheels, steering columns and steering boxes; parts thereof: Parts: For other vehicles: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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). Additionally, 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. In the present case, the main components of the ball joints and pitman arms are sourced from Malaysia. Furthermore, the Chinese components are further machined and integrated with the Malaysian components, thus, losing their individual identities and becoming parts of the finished articles. As a result, the substantial transformation occurs in Malaysia, and the country of origin of the Ball Joints, Model Numbers X-00024J, X-0241J and X-00039J, and Pitman Arms, Model Numbers BT-7087J-42CrMo and BT-7142J, will be Malaysia for marking purposes and for purposes of applying current trade remedies under Section 301 and additional duties. 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 subheadings 8708.80.6590 and 8708.94.7550, 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 Malaysia 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 subheadings 8708.80.6590 and 8708.94.7550, 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/. 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) Denise Faingar Acting Director National Commodity Specialist Division