OT:RR:NC:N2:206
Yiqin Weng
Maersk Logistics & Services China Ltd
26F, No. 757, Mengzi Road, Huangpu District
Shanghai
China
RE: The country of origin of disc brake rotors
Dear Yiqin Weng:
In your letter dated August 18, 2025, you requested a country of origin ruling on five disc brake rotors, which
you filed on behalf of Winhere (Thailand) Co., Ltd.
The articles under consideration are disc brake rotors, Part Number YH2998-662998, YH20754-6620754,
YH20984-6620984, YH21300-6621300, and YH21436-6621436, used in passenger vehicles. The dimensions
are as follows:
Part Number YH2998-662998 is 13.22” in overall diameter (OD), 2.65” in overall height (OH), 1.04”
in thickness (THK), and 23.8lbs in weight.
Part Number YH20754-6620754 is 13.78” in OD, 1.95” in OH, 1.26” in THK, and 28.8lbs in weight.
Part Number YH20984-6620984 is 12.64” in OD, 2.004” in OH, 1.06” in THK, and 21.96lbs in
weight
Part Number YH21300–6621300 is 11.02” in OD, 1.75” in OH, 0.84” in THK, and 14.07lbs in
weight.
Part Number YH21436-6621436 is 11.65” in OD, 1.94” in OH, 0.98” in THK, and 16.8lbs in weight.
You indicate that the raw material (scrap steel) for all five disc brake rotors is purchased from a vendor in
Thailand, and undergoes melting, moulding, pouring, fettling, quality inspection, rough machining,
semi-machining, drilling, fine machining/grinding, balancing, marking, online inspection, and packing in
Thailand. Stickers and other foundry auxiliary materials are sourced from China and incorporated into each
disc brake rotor in Thailand, along with the Thai corrugated cartons, plastic bags, and a shared pallet. The
cost of the Thai components and labor amounts to over 99.59 percent of the total cost for each disc brake
rotor.
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).
In the present case, the scrap steel is substantially transformed into each disc brake rotor in Thailand,
rendering it a new name, character, and use. The Chinese components, once incorporated into the brake rotor,
lose their individual identities and become parts of the rotors. Therefore, the country of origin for the disc
brake rotors, Part Number YH2998-662998, YH20754-6620754, YH20984-6620984, YH21300-6621300,
and YH21436-6621436, 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)
Denise Faingar
Acting Director
National Commodity Specialist Division