The country of origin of a steering tie rod end assembly

N354638 October 29, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Yicheng Hou Thaifu Automotive Co., Ltd. 19/33 Moo 5, Banbueng Banbueng 20170 Thailand RE: The country of origin of a steering tie rod end assembly Dear Mr. Hou: In your letter dated October 6, 2025, you requested a country of origin ruling on a steering tie rod end assembly for marking purposes and for purposes of applying trade remedies under Section 301, of the Trade Act of 1974, as amended, from China. The article under consideration has been identified as a Steering Tie Rod End Assembly, Part Number TF-NA-TREAY-01, which is an aftermarket good used in passenger vehicles. The assembly, also known as a tie rod assembly, provides directional control for vehicles. It is made primarily of steel with plastic and rubber components and weighs approximately 5lbs. The tie rod assembly consists of ball studs, a steering rod, ball stud shell, dust cover, dust boot, cotter, pin, castle nut, and plastic seats. You state that the raw materials, steel bars, are sourced from China and shipped to Thailand for further processing. In Thailand, the steel bars undergo cutting, heat treatment, and forging, thereby become rough ball studs (RPBP-0003 and RFBP-0002) and steering rod (RFTRE-0001). Rough ball stud RPBP-0003 then undergoes machining of the bottom side, middle section, neck section, head section, and thread rolling. Rough ball stud RFBP-0002 undergoes CNC machining, cotter pin hole drilling, detailed machining of the head section, and thread rolling. Rough steering rod RFTRE-0001 undergoes hole drilling, CNC facing, chamfering and grooving, edges cutting, and tapping and milling. The ball stud shell forging is sourced from China and undergoes machining of the top section and the end face, finishing the inner hole, and thread rolling in Thailand. Finally, the machined ball stud shell, ball studs, and steering rod are assembled together with the cotter pin, castle nut, and plastic seats from China and dust cover and dust boot from Thailand in Thailand. 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). 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 machining operations performed in Thailand for the ball stud shell and the assembly of all components together do not result in a substantial transformation. However, the steel bars from China are substantially transformed into identifiable ball studs and steel rod in Thailand. Since the ball studs and steel rod are major components that impart the character of the entire steering tie rod assembly, the country of origin will be Thailand for marking purposes and trade remedies under Section 301 will not apply. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division