OT:RR:NC:N2:206
Ms. Jie Tan
JT Law Services, PC
901 North Broadway, Suite 20
White Plains, NY 10603
RE: The country of origin of a brake caliper
Dear Ms. Tan:
In your letter dated February 20, 2026, you requested a country of origin ruling on a brake caliper, on behalf
of your client, Yusin Machinery (Malaysia) Sdn Bhd.
The article under consideration has been identified as a brake caliper, part number EX851005M. The brake
caliper is a critical component incorporated into the disk brake system in a motor vehicle. The primary
function of the subject merchandise is to apply pressure to the brake pads, which in turn creates friction
against the brake rotor or disc. The applied friction then slows the motor vehicle, creating a controlled stop.
The brake caliper fits over the rotor similar to a clamp.
The brake caliper under consideration consists of a caliper body, which is made in Malaysia, and a piston,
seal ring, rubber sleeve, and bleeder from China, which are imported to Malaysia for further assembly with
the caliper body. To create the caliper body, raw aluminum from Malaysia is smelted to produce molten
aluminum and then poured into casting molds, creating the initial caliper blank. This step is followed by the
removal of excessive waste materials, further heat treatment, and sandblasting, which creates the finished
brake caliper blank. The brake caliper blank is further processed by adding bore, mounting holes, annular and
sleeve grooves, and the arc shape to the caliper cylinder body in Malaysia. The caliper body is then
assembled with the piston, seal ring, rubber sleeve, and bleeder. Finally, the product is tested for quality
assurance and packaged for importation into the United States.
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).
CBP previously ruled on a similar scenario in New York Ruling N355045, dated November 17, 2025. In this
ruling, we stated that the caliper body from Thailand was the largest component that clamped directly onto
the brake rotor to stop it from spinning. This office also noted that the value of the caliper body was
significantly higher than the value of other components imported from China and the final assembly of all
components into the complete brake caliper also occurred in Thailand. As a result, we ruled that the country
of origin was Thailand.
Here, too, the caliper body from Malaysia is the largest component that clamps directly onto the brake rotor
to stop it from spinning, and the value of the caliper body amounts to 86 percent of the total cost. Thus, it is
the opinion of this office that the caliper body imparts the character of the entire assembly. Furthermore, the
final assembly of all components also occurs in Malaysia. Therefore, the country of origin of the brake
caliper, model EX851005M, will be Malaysia.
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