OT:RR:NC:N1:103
Lynlee Brown
Ernst & Young LLP
18101 Von Karman Ave., # 1700
Irvine, CA 92612
RE: The country of origin of linkage pins
Dear Ms. Brown:
In your letter dated March 19, 2026, you requested a country of origin ruling on behalf of your client, Dong
Xing (Thailand) Company Limited.
The merchandise under consideration consists of two linkage pins, referred to in your submission as a Pin
(part number 3506277-03) and a Pin Assembly (part number 3506311-05). The linkage pins are used in
excavators or loaders to attach the boom to the body, the boom to the stick, the bucket to the rocker arm, or
other similar connections. The pin is described as a cylindrical rod, while the pin assembly is described as a
cylindrical rod with a cut-to-shape plate welded to one end.
The manufacturing process begins in China, where bars of hot-rolled round steel are cut to the required
lengths. These bars are then heat treated using a quenching and tempering process before they are sent to
Thailand.
In Thailand, the bar is machined to shape and treated using an induction hardening process. Afterwards,
workers drill and then tap holes that will be used to inject oil to lubricate the pin. The pin continues to the
next station where the ends are chamfered, and a cylindrical grinding machine is used to finish the outer
cylindrical surface, conical surface, and face of the shoulder end. This process, together with polishing,
prepares the pin for electroplating, which deposits a chromium layer to improve wear resistance and prevent
corrosion. To create a pin assembly, an additional plate is welded to one end of the pin.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling
Letter 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).
Based on the information provided with your submission, it is our view that the operational steps that occur
in Thailand transform the cylindrical steel bar into linkage assemblies, articles with a name, character, and
use distinct from the article exported from China. As such, and based on the totality of the circumstances, the
country of origin of the Pin (part number 3506277-03) and Pin Assembly (part number 3506311-05) 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 Paul Huang at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division