The country of origin of a control arm

N355929 November 26, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Matthew Solomon White & Case LLP 701 Thirteenth Street, NW Washington, DC 20005 RE: The country of origin of a control arm Dear Mr. Solomon: In your letter dated November 10, 2025, you requested a country of origin ruling on a control arm for purposes of applying trade remedies under Section 301 and additional duties, which you filed on behalf of Mevotech, Inc. The article under consideration is a control arm, Part Number CMS50189, which is used in passenger vehicles. The control arm is component of a vehicle suspension system that connects the wheels to the vehicle chassis. It provides a connection and pivot point between the vehicle suspension and chassis and helps to maintain the correct wheel tracking and position. The control arm consists of a control arm body and bush assembly from China and ball joint assembly and hardware from India. You state that the Chinese control arm body and bush assembly is sent to India where it undergoes final assembly with India sourced components. In India, the component parts (coated control arm, ball joint, and bushes) are inspected. Then, using a hydraulic press, the ball joint is affixed to the control arm, followed by sealing/crimping. After that, the boot ring is attached to the assembly and grease is applied to the ball joint. The boot cover is then attached to the assembly, and the spiral ring clip is attached to the assembly using controlled machine. The bushes are then attached to the assembly by a hydraulic press, and the castle nut and protection cap are attached to the assembly manually. Finally, the control arm assembly is inspected, rust prevention oil is applied, and the completed assembly undergoes packing and labeling. 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). It appears that the processes performed in India are not complex enough to render a substantial transformation. The Chinese components are complete in their original state as they arrive to India and do not physically undergo any change. Thus, we must identify the character of the entire control arm. You state that the character of the control arm is the ball joint and cite New York (NY) rulings NY N309252, dated February 25, 2020, NY N339304, dated May 3, 2024, and NY N341829, August 29, 2024, to substantiate your analysis. In all three cited rulings, CBP determined that the character of a control arm is the ball joint. As a result, we agree with your position and the country of origin of the control arm, Part Number CMS50189, will be India for purposes of applying trade remedies under Section 301 and additional duties. 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division