The country of origin of a hydraulic shock absorber

N353886 October 6, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Qi Zhou Qie Heng Auto Parts (Thailand) Co., Ltd. 821/7 Moo.5, Khaokhansong Subdistrict Sriracha District 20110 Thailand RE: The country of origin of a hydraulic shock absorber Dear Ms. Zhou: In your letter dated September 18, 2025, you requested a country of origin ruling on a hydraulic shock absorber. The article under consideration has been identified as a Hydraulic Shock Absorber (Model Number A011520), which is a strut assembly designed for use in the suspension system of motor vehicles. It consists of a shock, coil spring, strut mount, bumper stop, strut dust shield, upper spring bumper, and upper spring seat. The article is imported fully assembled as a complete working strut. The function is to control the rebound and compression of the suspension springs, ensuring stability, comfort, and road handling. You state that the shock absorber is manufactured in Thailand with components sourced from China and Thailand. According to the bill of materials (BOM) supplied with your request, the shock and strut mount are produced in Thailand, while the coil spring, bumper stop, strut dust shield, upper spring bumper, and upper spring seat are sourced from China. In Thailand, the components are joined together and packaged for after-market sale to distributors and automotive repair shops for installation in passenger cars and light trucks. 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). It has been a long-standing CBP position that the mere combining of components together does not result in a substantial transformation. Therefore, we need to determine the character of the strut assembly. In New York Ruling N307541, dated December 11, 2019, this office discussed a suspension strut of a similar construction as the strut in your request. We determined that the shock absorber was the character of the entire strut assembly. Furthermore, HQ H310543, dated May 8, 2020, reaffirmed this determination and found that the shock absorber is the character of the strut assembly. In the instant case, the shock absorber is said to be sourced from Thailand. As a result, the country of origin of the entire strut assembly, Hydraulic Shock Absorber (Model Number A011520), 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division