CLA-2-87:OT:RR:NC:N2:206
John Kenkel
International Trade Law Counselors, PLLC
8647 Richmond Hwy, Suite 623
Alexandria, VA 22309
RE: The tariff classification and country of origin of inner and outer tie rods
Dear Mr. Kenkel:
In your letter dated August 7, 2025, you requested a tariff classification and country of origin determination
ruling on inner and outer tie rods, which you filed on behalf of GAA Automotive Technology Sdn Bhd.
The articles under consideration are Inner Tie Rods (Models D-40122 and D-40179) and Outer Tie Rods
(Models L-3315J, L-2050J, and L-2860J), which are used in passenger vehicles.
The inner tie rods are parts of the automobile steering mechanism, which directly affect the stability of the
automobile handling, safety of operation and service life of the tires. The inner tie rods are responsible for
transmitting the movement of the steering rocker arm to the steering knuckle arm; they also ensure the
correct movement relationship between the left and right steering wheels. The inner tie rod sub-assemblies
include ball pin, ball socket and other accessories. One end of a single tie rod is connected to the tie rod ball
head, and the other end is connected to the steering gear to achieve accurate steering control.
The outer tie rods are often used in conjunction with inner tie rods, with one end connected to the tire. They
can achieve precise steering of the car, making the car run more smoothly and accurately. As key components
connecting the suspension and the stabilizer bar, the outer tie rods are mainly responsible for the transmission
of force between the vehicle suspension and the stabilizer bar. They can effectively ensure the stability and
balance of the suspension system during driving, thereby improving the vehicle's handling performance. The
outer tie rod sub-assemblies include boot, bushing, ball pin, ball socket, backing plate and other accessories.
You state that the housing and the ball pin of the inner tie rods are sourced from Malaysia, while the clip, ball
socket, nut, gaskets, brackets, and cable ties are sourced from China and imported into Malaysia to be
assembled to create the complete inner tie rods. The outer tie rods are also assembled in Malaysia from the
boot, housing, and ball pin from Malaysia, and the nut, bolt, spiral ring clips, ball socket, backing plate, glib,
and gasket from China.
You suggest that the inner and outer tie rods be classified in subheading 8708.80.1600, Harmonized Tariff
Schedule of the United States, (HTSUS), which provides for “Parts and accessories of the motor vehicles of
headings 8701 to 8705:Other parts and accessories: Other: Other: Other: Other: Suspension systems and parts
thereof (including shock absorbers): Parts: Other.” We disagree. The inner and outer tie rods are neither
suspension systems nor parts of suspension systems. They connect the steering rack to the wheels. As a
result, they are better described as steering parts than suspension parts.
The applicable subheading for the Inner Tie Rods (Models D-40122 and D-40179) and Outer Tie Rods
(Models L-3315J, L-2050J, and L-2860J) will be 8708.94.7550, HTSUS, which provides for “Parts and
accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Steering wheels,
steering columns and steering boxes; parts thereof: Parts: For other vehicles: Other: Other.” The general rate
of duty will be 2.5 percent ad valorem.
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).
The assembly process described for the inner and outer tie rods do not appear to be complex enough to render
a substantial transformation. None of the components transform into a new article after being turned, laser
marked, greased, pressed into one another, tested, and packaged in Malaysia. Thus, we look to the country of
origin of the major components of each tie rod assembly. It is the opinion of this office that the housings and
ball pins in both assemblies impart the character of the inner and outer tie rods. Therefore, the country of
origin for the Inner Tie Rods (Models D-40122 and D-40179) and Outer Tie Rods (Models L-3315J,
L-2050J, and L-2860J) will be Malaysia.
Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile
parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05,
as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading
8708.94.7550, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Malaysia will be
subject to an additional ad valorem rate of duty of 19 percent. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheading 8708.94.7550, HTSUS, listed above.
The tariffs and additional 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/.
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)
James Forkan
Acting Director
National Commodity Specialist Division