OT:RR:NC:N2:201
Youngwon Yoon
W Customs
209 Hakdongro, Gangmamgu,
Seoul, 06052
South Korea
RE: The country of origin of Hydraulic Cylinders for mechanical equipment
Dear Mr. Yoon:
In your letter dated July 11, 2025, you requested a country of origin ruling for purposes of applying Section
301 duties, on behalf of your client, DY Power Corporation, located in Gyeongsangnam-do, South Korea.
The following ruling is based on the information submitted.
DY Power pioneered the production of hydraulic cylinders for construction equipment in Korea. You state
that your main products are hydraulic cylinders that are used for Excavator, Aerial Work Platform, Fork Lift,
Wheel Loader and Backhoe Loader. You currently source the majority of the 57 raw materials used in the
production of the cylinder. While some of the parts are procured from China, the EU, and Japan. You state
that DY Power plans to replace five (5) of the Korean-sourced materials with Chinese alternatives.
Due to this change in the origin of many sourced parts, you submitted this request to determine the country of
origin of the final product—hydraulic cylinders.
A hydraulic cylinder is a core component in hydraulic systems that converts hydraulic energy into
mechanical energy to generate linear motion. This device is used across various industries—construction,
manufacturing, agriculture, and automotive—to push, pull, lift, or lower heavy loads. You state that is your
opinion that the current Harmonized Tariff Schedule of the United States (HTSUS) code for these types of
hydraulic cylinders is 8412.21.0075. We do not, according to the evidence provided, dispute this HTSUS
classification.
Excavator cylinders are specialized hydraulic cylinder used in excavators to convert pressurized hydraulic
fluid into powerful linear motion and force, enabling essential functions like digging, lifting, and rotating.
These heavy-duty cylinders are built to withstand extreme pressure and heavy loads.
Forklift cylinders are essential components in a forklift's hydraulic system, enabling precise control over
lifting, tilting, and positioning of loads. They convert hydraulic pressure into mechanical force, facilitating
various movements crucial for material handling tasks.
Wheel Loader Cylinders are hydraulic cylinders used in wheel loaders to provide the force and motion
required for various tasks, primarily lifting and tilting the bucket and steering the machine.
Backhoe Loader cylinders are hydraulic component that uses pressurized fluid to generate linear force and
movement, enabling the backhoe's various functions. Among the four types of hydraulic cylinders listed
above, the product for which we are applying for a CBP ruling is the excavator cylinder.
In your request you enumerate the 57 different parts that go into the manufacturing of a single hydraulic
cylinder. These parts include, but are not limited to:
Tubes
Collars
Inner/Outer Rings
Head Covers
Rods
Knuckles
Pins
Bushings
Seals
These materials include ones sourced from Korea, China, the EU, and Japan. The Bill of Materials (BOM)
shows that among the raw materials used; those sourced from Korea are the most numerous. You state that it
is your client’s intention to move the source country of five (5) of the parts to China. Those parts have been
identified as:
Collar
Head Cover
Rod
Knuckle
Rod Cover
Although the current supplier of the raw materials listed above is Korea, and there is a planned change to
China in the future, the specific Chinese supplier has not yet been determined. However, the
above-mentioned raw materials are all simple components that have not yet undergone the key processing
stages required for the hydraulic cylinder product to perform its function.
The manufacturing and processing of products exported to the United States, regardless of their original
COO, is currently performed in Korea. The manufacturing process of a hydraulic cylinder can be broadly
divided into four main steps:
1. Rod Part manufacturing
2. Rod All Group assembly
3. Tube Part manufacturing and
4. Connection of the Rod All Group with the Tube Part
Through this process, the finished hydraulic cylinder attains its designed purpose, characteristics, and
functionality.
Process Step Procedure Purpose of the Process
Rod Part -Prepare raw steel rod The raw steel rod is transformed through
Production -Machine outer diameter & piston area precision machining, corrosion protection,
-Grind, buff, and plate and surface hardening into a high-precision
-Weld knuckle component that serves as a core part of the
Rod All Group.
Rod All Group -Assemble Rod Cover Group, Piston The Rod All Group is assembled to convert
Assembly Group, Piston Nut, etc. individual components into a single
-Fasten all components operating unit capable of transmitting
hydraulic force and performing linear
motion inside the tube.
Tube Part -Cut and process hollow steel tube To transform the hollow steel tube into a
Production -Weld Collar and Head Cover precision structure capable of withstanding
-Assemble Inner Ring hydraulic pressure and controlling internal
fluid flow, the tube is manufactured with
sealing functionality to ensure smooth
movement of the rod.
Assembly of -Connect Rod All Group and Tube Part Combines subassemblies into a complete,
Rod All Group using connecting components functional hydraulic actuator capable of
with Tube Part real-world mechanical operation.
All the manufacturing processes mentioned above are carried out in South Korea. At each stage, not only are
parts assembled, but the form, function, and characteristics of the materials are significantly altered to meet
the performance requirements of the hydraulic cylinder.
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).
It is the opinion of this office that, based on the information provided, the processes that take place in South
Korea substantially transform the individual parts and components sourced from China, EU, and Japan. to
complete the Hydraulic Cylinders.
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 Matthew Sullivan at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division