The country of origin of a suspension strut

N360325
April 28, 2026
OT:RR:NC:N2:206
CATEGORY: Origin Jun Wang ADD Suspension (Thailand) Co., Ltd. No. 88/14 Moo 8, Thakam Subdistrict, Bangpakong District, Chachoengsao 24130 Thailand RE: The country of origin of a suspension strut Dear Mr. Wang: In your letter dated April 1, 2026, you requested a country of origin ruling on a suspension strut. A sample was submitted with your request and is being returned to you. The item is a strut, Model DGN51619, which serves as a pivotal component of the vehicle suspension system and as an integrated structural assembly, the strut includes a shock absorber and other additional suspension components. The strut has multiple functions, such as damping, supporting the vehicle’s weight, and serving as a mounting point for steering and other suspension components, directly affecting steering geometry. It is designed for use with specific vehicle models, including cars, sport utility vehicles (SUVs), and pickup trucks. It cannot be used universally, and must correspond strictly to the specific vehicle. The strut operates autonomously, responding to vehicle shocks and bumps without requiring an external power source. The strut mainly consists of a reservoir tube assembly, a spring seat, a connecting bracket, a piston rod, a working cylinder, and other components. The strut is manufactured from steel and metal components, rubber, oil, and chemicals, with its working parts and surfaces painted or electrophoresed. According to the bill of materials (BOM) supplied with your request, the reservoir tube assembly, working cylinder, compression valve assembly, rebound valve assembly, rod guider, oil seal, piston rod, stopper cushion, oil, paint, nut, dust cover, and other components are imported from China to Thailand for further assembly. You state that the steel pipe for the reservoir tube undergoes multiple deep processes including shaping, cleaning, and further inspection in Thailand. The spring seat, connecting bracket, and bottom cap into the reservoir tube assembly through welding and other procedures in Thailand. After that, the piston rod and working cylinder undergo inspection, cleaning, polishing, and rust prevention. The reservoir tube assembly is then assembled together with the spring seat, piston rod, working cylinder, compression valve assembly, rebound valve assembly, rod guider, oil seal, and oil into the strut through various procedures in Thailand.

When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). In the present case, the tubes undergo significant processes before becoming parts of the strut. Although minor components are imported from China in their finished state, the reservoir tube and piston rod are formed in Thailand. Furthermore, the final assembly also occurs in Thailand. As a result, it is the opinion of this office that the country of origin of the complete suspension strut, Model DGN51619, 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