CLA-2-87:OT:RR:NC:N2:206
John Kenkel
International Trade Law Counselors, PLLC
8647 Richmond Hwy., Suite 623
Alexandria, VA 22309
RE: The tariff classification and country of origin of a stabilizer link
Dear Mr. Kenkel:
In your letter dated April 14, 2026, you requested a tariff classification and country of origin determination
ruling on behalf of ASSP (Thailand) Co., Ltd.
The article under consideration is a stabilizer link, Model No.: XNK20392, which is a core safety and
functional component of automotive suspension systems. It connects the suspension to the vehicle body,
buffers road shocks and vibrations, maintains constant tire-to-ground contact, and ensures the vehicle’s
traction, stability, and overall control performance.
The stabilizer link consists of a main body (two housings and a rod), two ball pins and auxiliary components,
such as ball seats, sealing plates, dust covers, snap rings, protective covers, nuts, grease, etc. The raw blanks,
which are mainly unformed rods and bars for the main body, and ball pins are imported from China to
Thailand for further processing.
In Thailand, the stabilizer link main body blanks undergo a full set of precision processing: stamping into
formed blanks, CNC finish machining with strict dimensional tolerance control, welding of the rod and
housings into an integrated main body, secondary finish machining to form assembly-matched rivet openings,
and surface treatment to achieve corrosion resistance and a smooth, scratch-free finish.
The ball pin blanks undergo CNC machining of the shank, ball pin head machining to ensure high roundness
and fine surface roughness, thread rolling of the shank, and subsequent surface treatment and spherical
polishing for surface optimization also in Thailand.
Then, the processed stabilizer link main body and ball pin are assembled with all auxiliary components from
China, namely ball seats, grease, sealing plates, dust covers, snap rings, protective covers and nuts in
Thailand. Finished stabilizers undergo quality inspection and then are labeled, sealed, packaged, and
warehoused for shipment.
The applicable subheading for the stabilizer link, Model No.: XNK20392, 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 of the stabilizer link substantially transform from rods and bars into
an identifiable link body and ball pin in Thailand. where they are formed. The rest of the Chinese
components lose their individual identities and become parts of one unit. As a result, a substantial
transformation occurs in Thailand. Therefore, the country of origin for the stabilizer link 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