OT:RR:NC:N1:102
Jie Tan
JT Law Office
901 North Broadway, Suite 20
White Plains, NY 10603
RE: The country of origin of a brake master cylinder
Dear Jie Tan:
In your letter dated March 19, 2026, you requested a country of origin ruling on behalf of your client, Yusin
Machinery (Malaysia) Sdn Bhd. A description of the final assembly process was provided in the submission.
The product at issue is a brake master cylinder, model number EX0206(AH)-1M. The brake master cylinder
is a component of a disc brake system used in a motor vehicle. In use, when a driver depresses the brake
pedal, the internal pistons of the master cylinder move in a linear manner, and this allows hydraulic fluid to
flow from a reservoir to the pistons of each brake caliper, pushing the brake pads outward.
With respect to origin, each brake master cylinder is assembled in Malaysia using components sourced from
Malaysia and China. The final assembly that occurs in Malaysia consists of manually inserting a piston, a
push rod, two snap rings, two rubber gaskets, and a valve assembly, all from China, into an aluminum
housing that is cast and finished in Malaysia. The finished product is then inspected, sealed and packaged
ready for importation.
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).
Here, the final assembly of the brake master cylinder consists of inserting components into a housing and
then completing a sealing process. While these processes are not particularly complex, this office has
considered the totality of the circumstances, in that the final assembly occurs in Malaysia and the origin of
the housing is Malaysia, a component that is significant when considering its role, bulk and value. Based on
these considerations, this office believes the origin of the brake master cylinder is 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 Sandra Martinez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division