The country of origin of coil springs

N348322
May 20, 2025
OT:RR:NC:N1:164
CATEGORY: Origin Heidi Wolfe BWI Group 12501 Grand River Ave. Brighton, MI 48116 RE: The country of origin of coil springs Dear Ms. Wolfe: In your letter dated April 28, 2025, you requested a country of origin ruling on coil springs. Technical information was submitted with your The items under consideration are described as coil springs for use in automotive suspensions. In your letter, you state that coil springs control and relieve vibration, noise, and the impact transmitted into an automotive vehicle while driving. In addition, coil springs maintain the movement of the tire which positively affects the condition of the automotive suspension and thus the vehicle. The subject coils springs are mainly composed of grade SAE 9254 silicon-chromium spring steel and will be imported in different sizes. Manufacturing of the coil springs begins in Korea with steel rod as the primary raw material. The rod undergoes cold processing operations which includes straightening, shot blasting, shearing, and polishing. At this point, the rod goes through eddy current and ultrasonic testing. In some cases, the rod also undergoes centerless grinding prior to packing and shipment for export from Korea. The steel rod is shipped to the United States in diameters of 16.45 millimeters (mm) to 19.3 mm and in lengths of 1865 mm to 2815 mm. In the United States, the imported steel rod is heated in a furnace up to 980 degrees Celsius which causes physical changes in the steel and makes it malleable. Once heated, the steel rod is coiled around a mandrel according to a specified shape. Following that, the formed coil spring is cooled down rapidly by quenching in a tank to increase the mechanical properties of the steel. Then, the quenched coil spring is reheated at constant temperature to increase strength. At this point the coil springs undergo hot setting, shot peening for surface quality, and cold setting. The coil springs are then pretreated with a phosphate coating for corrosion resistance and to improve paint adherence. Finally, the coil springs are painted for surface integrity and tested under loads. 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. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 C.F.R. 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 C.F.R. 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 instant case, the steel rod from Korea is imported into the United States as straight lengths of steel. During the forming phase of the manufacturing process, the heated steel rods are coiled around a mandrel to specifications. The steel rod transforms from a straight length of steel into a spiral of successive coils capable of elastically expanding and contracting under force. A straight length of steel rod is incapable of functioning in this manner due to the absence of successive coils which form the identifiable and functional shape of a coil spring. It is the opinion of this office that during the manufacturing process in the United States, the steel rod is transformed into an article with a new name, character, and use than what was present prior. It is transformed from a straight steel rod, incapable of expanding and contracting as a spring, into a coil spring. Accordingly, the country of origin of the coil springs for marking purposes is the United States. If a good is determined to be an article of U.S. origin, it is not subject to the country of origin marking requirements of 19 U.S.C. §1304. Whether an article may be marked with the phrase “Made in the USA” or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580 on the propriety of proposed markings indicating that an article is made in the U.S. 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 Taylor at [email protected].
Sincerely,
(for) Steven A. Mack Director National Commodity Specialist Division