The country of origin of vehicle gas springs

N353488 October 2, 2025 OT:RR:NC:N5:121 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of vehicle gas springs Dear Ms. Murrin: In your letter dated September 9, 2025, you requested a country of origin ruling on gas springs on behalf of Xiangjun DMA Advanced Lift Technologies (Thailand) Co., Ltd. The merchandise under consideration is described as vehicle gas springs, part numbers 121E25A2363, 121E25A0095, 121D06A0063, 121G30A0100, and 121H22A0013. You state these gas springs are of a kind used in vehicles, primarily to support the hood and trunk door when opened. All five model numbers are functionally the same but will have minor differences in the components assembled to the finished products. 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 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). You describe a manufacturing process in which the precision steel pipe, plastic components, seal, sealing ring, guide sleeve, and end cap originate in China. Those components are shipped to Thailand to be assembled with Thai-origin piston rod, piston, gasket, gas spring oil and nitrogen gas into the finished gas springs. In Thailand, the Chinese-origin pipe is cut to length, the ends are chamfered, shaped into a bell-mouth configuration and then cleaned. Next the inner wall of the tube is grooved, one end is sealed, and a Chinese-origin end cap is welded on the closed end. The Thai-origin piston and gasket, and the Chinese-origin sealing ring are then riveted to the non-threaded end of the Thai-origin piston rod. The gas spring oil of Thai-origin is injected into the cylinder tube, and the riveted piston rod, sealing ring, and guide sleeve are further assembled to the cylinder tube. The cylinder tube flanging is formed and the exterior near the piston rod is crimped. The gas spring then is tested, spray painted, assembled with plastic connectors on both ends, marked with specifications and identification, and then packaged for export to the United States. It is of the opinion of this office that the Chinese components undergo processing that is sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In addition, it is our opinion that together the piston rod and piston hold the essential identity of the finished gas spring, and those components are manufactured in Thailand. Thus, from the details submitted, we agree that the country of origin for vehicle gas springs, part numbers 121E25A2363, 121E25A0095, 121D06A0063, 121G30A0100, and 121H22A0013, 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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division