The country of origin of a steering knuckle assembly

N360457
May 6, 2026
OT:RR:NC:N2:206
CATEGORY: Origin Edward Hayes Leake and Andersson 1100 Poydras Street, Suite 1700 New Orleans, LA 70163-1701 RE: The country of origin of a steering knuckle assembly Dear Mr. Hayes: In your letter dated April 6, 2026, you requested a country of origin ruling on a steering knuckle assembly, filed on behalf of EBI Transmission System (Thailand) Co., Ltd. The article under consideration has been identified as a steering knuckle assembly, Part Number EBSKB1099R (Customer Part Number 698-416), which is used in passenger vehicles. It is sometimes commercially referred to as a loaded knuckle. The knuckle is an automotive component part designed to connect the front wheel hub to the suspension and steering systems. It allows the wheels to pivot while supporting the vehicle's weight and houses the wheel bearings. It acts as a crucial link between tie rods, control arms, and braking components. The knuckle is mounted on the inner side of the front wheels at both ends of the front axle, allowing the wheels to turn and move up and down. It is comprised of a wheel hub, a knuckle blank, a hardware kit, and a back plate. The knuckle blank, which is an unfinished, raw piece of metal that is intended for further processing, is produced beginning with a bracket material that is then cast into the mold shape in China. You state that in this phase of the production process, the knuckle blank lacks the features to execute its intended end-function of becoming a finished knuckle that is subsequently integrated into the steering knuckle assembly. It is then exported to Thailand and undergoes machining operations including turning, milling, drilling, inner hole grinding, surface treatment and cleaning in Thailand. The hardware kits are prepared in Thailand and include bolts, nuts, shims, and bushings but sometimes vary depending on the components from car makers. Also in Thailand, the back plates are prepared from raw materials and are stamped and finished with a surface treatment. The wheel hubs are produced in Thailand beginning with the material preparation of the upper and lower flange inner and outer rings. It is then followed by forging, where ring materials are forged into upper flange

outer ring blanks and upper flange inner ring blanks. After that the product undergoes computer numerical control (CNC) machining, grinding, drilling, assembly and bolt pressing, and spin riveting in order to produce the finished wheel hub component that is ready for integration into the steering knuckle assembly. Finally, all components are integrated into a finished steering knuckle assembly through pressing the wheel hub into the knuckle body, installing the back plate, performing quality testing, installation of hardware kits, and packaging the finished steering knuckle assemblies for export. 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). Based on the submission and supporting documents, the knuckle blank is not the only important component in the fully loaded assembly. The final product is very different from the knuckle blank. The purpose of the assemblies is to “connect the front wheel hub to the suspension and steering systems.” In the present submission, the hub itself is included in the assembly and is completely forged and manufactured in Thailand. The hubs are also essential in the connecting the wheel to the axle and enabling the vehicle’s wheels to function. See Complete Steering Knuckle & Hub Assemblies | MOOG Parts. As such, it can be said that there are at least two important components to the subject product. In HQ H327997, dated Apr. 10, 2023, we stated that “[i]n instances in which component production or assembly occurs in multiple countries and no single country’s operations dominate the manufacturing operations, CBP has looked to the location at which final assembly occurs.” Therefore, the country of origin of the steering knuckle assembly, Part Number EBSKB1099R, 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