OT:RR:NC:N2:206
Aaron Marx
Crowell & Moring, LLP
1001 Pennsylvania Ave NW
Washington, DC 20004
RE: The country of origin of a brake caliper
Dear Mr. Marx:
In your letter dated October 20, 2025, you requested a country of origin ruling on a brake caliper, which you
filed on behalf of Q-Thai Auto Parts Co., Ltd.
The article under consideration is a brake caliper, model 20100890, which is a component of a disc brake
system in a vehicle. Its primary function is to transform hydraulic pressure into clamping force, applying
pressure to the brake pads, which in turn creates friction against the brake rotor to slow down or stop the
rotation of the wheel. The brake caliper consists of a caliper body, caliper bracket, pistons, piston dust covers,
rectangular rings, guide pin, locate pin, guide pin dust covers, guide pin bolts, and bleed screw.
The caliper body is made in Thailand from sand, pig iron, and other materials. All other components are
sourced from China and imported into Thailand for further processing. In Thailand, the bracket pin holes and
caliper piston chambers undergo deburring and flushing. Then, installation of the bleed screw and grease
injection into the piston chamber occurs. After that, the rectangular ring is first fitted into the caliper groove,
followed by placing the dust boot into the piston groove. The piston itself is then pressed into the chamber.
Once high and low airtightness pressure testing is done, the bracket is assembled. The dust boots for the
guide pins are put in place, and both slide pins and support pins are inserted into the bracket. The slide pin
bolts are inserted into the caliper lugs and connected to the guide pins. These bolts are then tightened
securely using a wrench. Finally, the complete product is packaged. A plug is inserted into the oil inlet, and
the caliper assembly is then placed in a plastic bag and packed in layers within a wooden case according to
packaging specifications.
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).
CBP previously ruled that the character of a brake caliper is the brake pads. See NY N351308, dated July 31,
2025, and NY N317253, dated February 23, 2021. However, in the current scenario, the caliper is imported
without any brake pads. Since the caliper body is the largest component that clamps directly on the brake
rotor to stop it from spinning and the value of the caliper body from Thailand amounts to 58 percent of the
total cost, it is the opinion of this office that the caliper body imparts the character of the entire assembly.
Furthermore, the final assembly of all components also occurs in Thailand. Therefore, the country of origin
of the brake caliper, model 20100890, 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 [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division