CLA-2-87:OT:RR:NC:N2:206
Mr. 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 tie rod assembly
Dear Mr. Kenkel:
In your letter dated April 1, 2026, you requested a tariff classification and country of origin ruling on a tie rod
assembly filed on behalf of ASSP (Thailand) Co., Ltd.
The tie rod assembly, model XNS10118L, is a core functional and safety component of the automotive
steering system responsible for transmitting steering motion, maintaining wheel alignment, and ensuring
precise steering and driving stability.
The tie rod assembly is composed of an outer tie rod and an inner tie rod. The outer tie rod consists of a
housing, a ball pin, a ball seat, a sealing plate, a dust cover, snap rings, a nut, a protective cover and grease;
the inner tie rod is made up of a housing, a ball seat and a ball pin, nut and grease. The key components,
including the blanks of outer and inner tie rod housings and ball pins, are imported from China, which are
raw blanks without any shapes matching semi-manufactured or finished parts. Other components, such as the
ball seats, sealing plates, dust covers, snap rings, protective covers, and nuts are imported in their finished
form from China.
The outer tie rod housing undergoes a full set of precision machining and enhancement processes starting
from blank forming. After that, rough machining is carried out, followed by finish machining to ensure the
dimensional accuracy. Subsequently, induction hardening is applied to improve the hardness and surface
treatment to prevent rust. Then precision thread machining (including drilling/tapping for internal threads and
thread rolling for external threads) is performed to meet the assembly matching requirements, with laser
marking finally conducted.
The inner tie rod housing is processed with targeted forming and machining processes. The raw blank is first
formed by stamping, and then finish machining is focused on the ball hole and the top of the housing, with
strict control over the dimensional deviation and geometric tolerance to ensure precision.
The outer tie rod ball pin undergoes shank machining, head machining, thread rolling, and spherical
polishing. The tie rod ball pin undergoes blank forming, machining, thread rolling and finally surface
treatment is performed, improving the service life and operation smoothness.
The processed outer/inner tie rod housings and ball pins are assembled together with the ball seats, sealing
plates, dust covers, snap rings, protective covers, nuts, and Thailand-produced grease. The finished tie rod
assembly undergoes surface cleaning, testing, labeling, sealing, packaging to ensure compliance with quality
standards.
The applicable subheading for the tire rod assembly, model XNS10118L, will be 8708.94.7550, 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: Steering wheels, steering columns and
steering boxes; parts thereof: Parts: For other vehicles: 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 major components of the tie rod assembly are substantially transformed from steel
blocks and bars into identifiable components, such as the outer/inner tie rod housings and ball pins in
Thailand. Other minor components that are imported from China then lose their individual identities and
become parts of the tie rod assembly in Thailand when assembled into the final product. As a result, a
substantial transformation occurs in Thailand. Therefore, the country of origin of the tie rod assembly, Model
XNS10118L will be Thailand 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 P. Forkan
Director
National Commodity Specialist Division