CLA-2-87:OT:RR:NC:N:2:206
John Kenkel
International Trade Law Counselors, PLLC
8647 Richmond Hwy, Suite 623
Alexandria, VA 22309
RE: The tariff classification and country of origin of a steering knuckle assembly.
Dear Mr. Kenkel:
In your letter dated January 29, 2026, you requested a tariff classification, and country of origin
determination ruling, which you filed on behalf of Viet Nam Haiya Technology Co., Ltd.
The article under review is a steering knuckle assembly, Item Number HYA1249-2, which is used with
passenger vehicles. The steering knuckle assembly integrates a steering knuckle, wheel hub bearing, and
wheel hub flange and is connected to the vehicle chassis suspension system via bolts and constant velocity
(CV) joints.
You state that the components of the steering knuckle assembly, such as the steering knuckle, bearing, and
flange, are made in China and imported to Vietnam in an unfinished state. In Vietnam, the steering knuckle
undergoes turning and drilling holes. The bearing undergoes grinding, super-finishing, and other
manufacturing processes to produce the precision raceways. The flange undergoes multiple precision turning
operations, drilling or tapping, grinding, and super-finishing to create a finished product. The components are
then assembled together with a China sourced nut, bolts, circlip, cages, seals, steel balls, shat head cover, and
mudguards in Vietnam.
The applicable subheading for the steering knuckle assembly, Item Number HYA1249-2 will be
8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and
accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Suspension systems
and parts thereof (including shock absorbers): Parts: Other: Other: Other.” The general rate of duty will be
2.5 percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,
indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to
indicate to the ultimate purchaser in the United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
A substantial transformation occurs when, as a result of manufacturing process, a new and different article
emerges, having a distinct name, character or use, which is different from that originally possessed by the
article or material before being subjected to the manufacturing process. See United States v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).
In National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993),
the court considered sockets and flex handles which were either cold formed or hot forged into their final
shape prior to importation, speeder handles which were reshaped by a power press after importation, and the
grip of flex handles which were knurled in the U.S. The court found that the drill bit blanks underwent no
significant change in character or use when they were processed into the finished drill bits in China. In other
words, the drill bit blanks had the very essence of the finished drill bits and the processing that was
performed in China did not change the shape, character or predetermined use of the drill bits.
Similarly in this case, the processes that occur in Vietnam do not render the Chinese components a new
name, character or use. The end-use of the components from China is predetermined before they arrive in
Vietnam for further processing and assembly, as the steering knuckle, bearing, and flange are recognizable as
such. Furthermore, the assembly of the components with the rest of the China sourced parts does not result in
a substantial transformation in Vietnam. As a result, it is the opinion of this office that the country of origin
of the steering knuckle assembly, Item Number HYA1249-2, will be China for marking purposes.
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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division