The country of origin of a strut assembly

N356030 December 3, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Hua Lin Jinbo Auto Parts (Thailand) Co., Ltd. House no. 88/6, Village no. 10, Khao Khan Song Subdistrict, Sri Racha District Chon Buri Province 20110 Thailand RE: The country of origin of a strut assembly Dear Mr. Lin: In your letter dated November 13, 2025, you requested a country of origin ruling. The item under consideration is Strut Assembly, Model Number S0099-A0330, which is used in passenger vehicles. You state that the main function of the strut assembly is to provide damping support to a vehicle's suspension system. The strut assembly consists of a shock absorber, strut mount, upper spring bumper, and upper spring seat from Thailand, and a coil spring, bumper stop, and strut dust shield from China. The shock absorber consists of a tube, connecting rod (piston), and lubricating oil from China, and spring seat, bottom cover, and lugs from Thailand. In Thailand, the components of the shock absorber are assembled into a complete shock absorber. The shock absorber is then inserted into the coil spring and combined with the rest of the components. 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). In the instant case, we find that combining all components together does not result in a substantial transformation. Furthermore, the assembly of the shock absorber in Thailand or the Chinese origin tube and piston does not transform the articles into a new product. The tube and piston have a predetermined use when arriving in Thailand for assembly. As a result, the country of origin of the shock absorber is China. In ruling HQ H310543, dated May 18, 2020, CBP determined that the character of a strut assembly is the shock absorber. Since the shock absorber in the present case is of Chinese origin, as indicated above, the country of origin of the entire strut assembly will also be China. 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