The country of origin of an idler assembly

N356156 December 8, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Youngwon Yoon W Customs 209 Hakdongro, Gangnamgu Seoul 06052 South Korea RE: The country of origin of an idler assembly Dear Youngwon Yoon: In your letter dated November 17, 2025, you requested a country of origin ruling on behalf of your client, Hyundai Minuteness Co., Ltd. The merchandise under consideration is referred to as an idler assembly, part number 14797201, and is described as an assembly used in the undercarriage of an excavator. It is composed of an idler wheel and a recoil spring subassembly. The idler wheel guides the track so that it can rotate continuously. The recoil spring assembly absorbs any shocks when the excavator is in motion. The idler assembly is assembled in South Korea using a process that is broken down into preassembling an idler wheel subassembly, preassembling a recoil spring subassembly, and final assembly. All of the components are manufactured in South Korea except for an idler rod, which is described as the central shaft of the idler wheel subassembly. The idler rod is sourced from China. The idler wheel subassembly requires the Chinese idler rod, an idler shell, brackets, bushings, pins, seals, and O-rings. The idler shell, described as a cylindrical body, is cast in Korea then machined to its final tolerances using turning, drilling, and tapping operations. Separately, the brackets are forged from steel materials and machined to their final specifications in Korea. Afterwards, the individual components are combined using an assembly sequence that involves cleaning and inspecting each item, pressing the bushings and seals into the idler shell, and using pins to secure the brackets to the shell. The recoil spring subassembly requires a rod, a spring, a yoke, a stop plate, a spacer, a bracket, and a nut. The yoke and bracket are forged from steel, then machined to their final tolerances. The rod, spacer, and nut are cut from steel bars then brought to a machining center where they are shaped using a turning process. Lastly, the individual components are fitted together, secured using screws and washers, and the subassembly is painted. Final assembly involves securing the idler wheel subassembly to the recoil spring subassembly using pins, screws, and washers. 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). Based upon your description of the manufacturing operations, we note that the only foreign component is a Chinese idler rod that accounts for less than three percent of the value of the finished assembly. All of the other components are manufactured in South Korea, and emerge with a new name, character, and use, different from that possessed by the materials (e.g., steel bars and metal alloys) from which they were formed. Thus, based on the totality of the circumstances, the country of origin of the idler assembly, part number 14797201, will be South Korea. 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division