The eligibility of the United States-Mexico-Canada Agreement (USMCA) of coil springs from Mexico

N355882 December 2, 2025 OT:RR:NC:N1:164 CATEGORY: Trade Programs Karen Hernandez Rosales Pie Consulting Av. Lazaro Cardenas 2224, Zona Loma Larga Oriente San Pedro Garza Garcia 66266 Mexico RE: The eligibility of the United States-Mexico-Canada Agreement (USMCA) of coil springs from Mexico Dear Ms. Hernandez Rosales: In your letter dated November 7, 2025, you requested a binding ruling on the eligibility of coil springs under the United States-Mexico-Canada Agreement (USMCA) on behalf of your client, Daewon Mexico S. de R.L. de C.V. The items under consideration are described as helical steel coil springs which will be used as critical components to provide suspension support and absorb loads in passenger car suspension systems. The submitted information states that the springs will be painted and imported with rubber pads on the ends to prevent noise from metal-to-metal contact after installation. As stated in your letter, the springs will be entirely manufactured in Mexico from Mexican and Korean components. The manufacturing process begins when straight lengths of alloy steel rod from Korea are heated and coiled around a mandrel according to specific design requirements. You explain that during this process the steel rod transforms from a straight bar into a spiral of successive coils which is capable of elastically expanding and contracting under force. After shaping, the coil is cut into individual spring pieces which undergo a tempering process to impart mechanical properties. Following that, the ends are polished, and the springs undergo shot blasting for surface treatment and additional heat treatment. At that point, the springs are painted by a zinc phosphate immersion process, powder coated with a black coating, marked, and assembled with two rubber pads from Korea on each end. Finally, the springs undergo strength testing and final inspections and are packaged in containers. The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”) 11 of the Harmonized Tariff Schedule of the United States (HTSUS) implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since the springs at issue contain non-originating ingredients, they are not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN 11(b)(iii). As you stated, the springs are classified under subheading 7320.20, HTSUS. The applicable rule of origin for goods classified under subheading 7320.20, HTSUS, is in GN 11(o), HTSUS, which provides: Chapter 73 - 17: A change to headings 7319 through 7320 from any heading outside that group. Based on the facts you provided, all raw materials are classified outside of headings 7319 through 7320, HTSUS. Consequently, the springs described above satisfy the requisite tariff shift rule under GN 11(o) and will be eligible for preferential treatment under the USMCA upon importation into the United States. 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division