The country of origin of hydraulic power steering rack

N360601
May 5, 2026
OT:RR:NC:N2:206
CATEGORY: Origin Guanhao Dai AIERFU (Thailand) Co., Ltd 188 Ban Len Bang Pa-in District 13160 Thailand RE: The country of origin of hydraulic power steering rack Dear Mr. Dai: In your letter dated April 9, 2026, you requested a country of origin ruling on a hydraulic power steering rack. The items under consideration are hydraulic power steering racks, SKU 8772, 8776, and 8783, which are components of a passenger vehicle’s steering system that helps steer the car. The models are similar in their features and undergo the same manufacturing processes. Each rack replaces the traditional mechanical linkage with a series of hydraulic cylinders and hoses. It is the hydraulic rack and pinion that converts rotational motion from the steering wheel into linear motion to control vehicle direction. The hydraulic steering system consists of several components, including a pump, reservoir, valves, and hoses. The pump is used to generate hydraulic pressure, which is then directed to the appropriate valve. The valve regulates the flow of hydraulic fluid and directs it to the appropriate hose. The hoses are responsible for carrying the hydraulic fluid to the vehicle's wheels. The entire system is typically located in the engine bay, just behind the vehicle's front bumper. You state that various components are sourced globally and shipped to Thailand. Also, the aluminum ingot for the housing is sourced in Thailand. Gravity die casting and high-precision machining are conducted in Thailand. In Thailand, the components undergo machining (for locally produced parts), assembly, torque fastening, hydraulic testing, and final inspection before export. Based on the bill of materials (BOM) supplied with your request, the steel cable baffle ring, two oil tubes, valve assembly, rack, oil cylinder, nut block and and two bushings are made in China and imported to Thailand. In Thailand, the Chinese components are assembled with the Thai-sourced steering housing, two rubber boots, o-ring, two clamps, two oil seals, and two inner rods, along with two Japan-sourced bearings and grease from Spain.

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 current case, the assembly of the components do not result in a substantial transformation. Although the Thai housing undergoes extensive processes, which renders its origin as Thailand, it is not the character of the steering rack. It is the Chinese rack and pinion, which is attached to the valve, that imparts the character of the steering rack. Furthermore, the hydraulic component of the steering rack is also made in China. As a result, the country of origin of the hydraulic power steering racks, SKU 8772, 8766, and 8783, will be China. 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