CLA-2-87:OT:RR:NC:N: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 control arms
Dear Mr. Kenkel:
In your letter dated March 24, 2026, you requested a tariff classification and country of origin determination
ruling on behalf of ASSP (Thailand) Co., Ltd.
The article under consideration has been identified as a control arm (Model XNA10197), which is a
component of the passenger vehicle suspension system. It flexibly connects the wheel to the vehicle body via
ball joints or rubber boots, effectively absorbing shocks and vibrations from rough roads. Its core functions
are to keep the tire in constant contact with the ground (ensuring strong traction, stable handling, and reliable
vehicle control) and shape the suspension geometry (critical for precise steering, reduced tire wear, and
handling forces during braking and acceleration).
The control arm is composed of three main parts: ball joint assembly (including ball pin, ball seat, housing,
sealing plate), arm body, and rubber boot. You state that these components are imported from China into
Thailand for further processing.
The ball pin undergoes shank machining, head machining, thread rolling, and drilling to meet assembly
compatibility requirements. This is followed by induction hardening, which transforms the surface
microstructure from austenite to martensite, increasing hardness from HRC28 to HRC50-55, and phosphating
coating for corrosion protection, concluding with polishing. The arm body undergoes shearing and blanking,
stamping, punching, trimming, hole flanging and welding, then welding slag grinding and surface treatment
for corrosion protection. The ball joint housing undergoes precision machining of the outer diameter, ball
hole and ball seat step, followed by induction hardening. The processed ball pin, housing, along with
China-sourced ball seats, and sealing plates are assembled with Thailand-produced Lithium-Based Grease
No.2 to form the complete ball joint assembly. Finally, the ball joint assembly, arm body, and China-sourced
rubber boots, dust covers, snap rings and protective covers are assembled. The finished control arm
undergoes surface cleaning, testing, labeling, sealing, and packaging to ensure compliance with quality
standards.
The applicable subheading for the control arm (Model XNA10197) 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: 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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 the present case, the main components from China, ball pin blank, ball joint housing blank, and the control
body arm blank, are not yet formed to their final shape. Based on the information provided, the blanks from
China are a steel bar for the ball pin, a cylindrical steel blank for the ball joint housing, and a steel plate for
the control arm body. It is only after the processes in Thailand they are formed into identifiable components
of a control arm. As a result, a substantial transformation occurs in Thailand, and the country of origin of the
control arm (Model XNA10197) 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 Liana Alvarez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division