The tariff classification and country of origin of automotive ball joints

N362278 July 7, 2026 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification; Origin TARIFF NO.: 8708.80.6590 John Kenkel International Trade Law Counselors, PLLC 8647 Richmond Hwy., Suite 623 Alexandria, VA 22309 RE: The tariff classification and country of origin of automotive ball joints Dear Mr. Kenkel: In your letter dated June 12, 2026, you requested a tariff classification and country of origin determination ruling, which you filed on behalf of ASSP (Thailand) Co., Ltd. The articles under consideration are automotive ball joints, models XNB20037, XNB20063 and XNB30110, used in suspension systems. You describe the automotive ball joints as core safety and functional components of the vehicle’s suspension, which connect the suspension and steering linkage mechanisms, enabling controlled multi-angle movement to adapt to dynamic driving and steering changes, They also bear the vehicle’s body load and road impact, maintain precise wheel positioning and optimal tire-to-road contact, and improve vehicle handling stability, driving safety and ride comfort while reducing abnormal tire wear. Each finished ball joint is composed of a housing, a ball pin, a ball seat, a sealing plate, a dust cover, snap rings, a protective cover and grease. Depending on the model, the product may also include nuts, bolts, spring washers and collars. The raw blanks for the housings and ball pins are imported from China to Thailand as unformed, unmachined blanks with no finished or semi-finished features. In Thailand, the carbon steel material is stamped by punch press to form a housing blank. The housing blank is then CNC machined to shape, including control of the housing internal hole, ball hole roundness and profile tolerance. Fixing holes are drilled using a vertical drilling machine, followed by surface treatment with a film to provide corrosion protection and a smooth, scratch-free surface. The ball pin is also processed in Thailand. The ball pin blank is machined on a CNC lathe to form the shank outer diameter, taper and related dimensional features. The ball pin for XNB20063 also undergoes thread rolling. The machined ball pin then undergoes spherical polishing to achieve a mirror finish. The processed ball joint housings and ball pins are then assembled with Chinese ball seats, sealing plates, dust covers, snap rings, protective covers, collars, nuts, spring washers, and Thai grease in Thailand. XNB30110 has a collar, while XNB20037 and XNB20063 do not require it. XNB20037 has no nuts, bolts, or spring washers. The finished ball joints then undergo quality inspection, packaging, and warehousing in accordance with standardized protocols. The applicable subheading for the ball joints, models XNB20037, XNB20063 and XNB30110, will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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. Friedlaender & 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Based on the information provided, the raw blanks for the ball pins and ball joint housings from China are steel bars not having any identifiable features. It is only after the processing in Thailand, they are formed into identifiable components of a ball joint. As a result, a substantial transformation occurs in Thailand, and the country of origin of the ball joints, models XNB20037, XNB20063 and XNB30110, will be Thailand. 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) James P. Forkan Director National Commodity Specialist Division