CLA-2-87:OT:RR:NC:N2:206
Jennifer Zhan
Thorx Sdn. Bhd.
No.134 & 135, Jalan 4, Kawasan Perindustrian Olak Lempit Banting
Selangor 42700
Malaysia
RE: The tariff classification and country of origin of a steering wheel cover
Dear Ms. Zhan:
In your letter dated September 4, 2025, you requested a tariff classification and country of origin
determination ruling.
The article under consideration is a Steering Wheel Cover (Part Number AC48302), which is designed to fit
over a standard automotive steering wheel. The primary use of the steering wheel cover is to enhance the grip
and provide a comfortable feel while driving, to protect the steering wheel from wear and tear, and to
enhance the overall interior appearance of vehicles. It consists of a polyurethane (PU) or polyvinyl chloride
(PVC) outer faux leather, PVC inner foam, and thermoplastic elastomer (TPE) inner ring.
You state that the white TPE granules and foam are sourced from Malaysia, while the PVC faux leather of
Chinese origin is shipped to Malaysia for further processing. In Malaysia, the white TPE granules are heated
in an oven machine, then melted in a melting machine. The molten white TPE granules then pass through a
mold for final shaping to be inner ring. Further, the PVC leather and foam undergo the lamination process to
be blended together, and then the blended PVC leather and foam is cut to shape to create a single PVC
leather roll. After that the outer PVC leather is stitched, and sewn together with the white TPE inner ring.
Finally, the product is inspected and packaged for import into the United States.
The applicable subheading for the Steering Wheel Cover (Part Number AC48302) will be 8708.99.8180,
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: Other:
Other.“ The 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).
According to the information provided and pictorial diagrams/videos, the foreign components lose their
individual identities and become parts of the steering wheel cover, as a result of processes in Malaysia.
Specifically, the lamination process with the Malaysian foam, as well as cutting to shape and sewing the
blended PVC faux leather and foam in Malaysia, substantially transform the components into a complete
steering wheel cover. As a result, the country of origin of the Steering Wheel Cover (Part Number AC48302)
will be Malyaia.
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. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.39, in addition to subheading
8708.99.8180, 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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division