The country of origin of inner tie rods

N361372May 26, 2026OT:RR:NC:N2:206
CATEGORY: OriginJinwoo KimCTR Co., LTD551, Gongdan-ro, Seongsan-gu,Changwon-si, Gyeongsangnam-do 51557South KoreaRE: The country of origin of inner tie rodsDear Mr. Kim:In your letter dated
May 8, 2026
, you requested a country of origin ruling on inner tie rods for markingpurposes and for purposes of applying trade remedies under Section 301, as amended, from China.The items under consideration are inner tie rods, Part Numbers 38220013/RIT0562 and 38010480/RIT0585,which are components of tie rod assemblies. You describe the assemblies as essential parts that connect thesteering rack and the steering knuckle, which is directly connected to the vehicle’s steering system. The innertie rods play a crucial role in the tie rod assembly as they are attached to the steering rack. They serve as thestarting point and consist of a threaded shaft that connects to the outer tie rod ends. This threaded shaft allowsfor adjusting the overall length of the tie rods, which are essential for achieving the proper alignment of thefront wheels. This adjustment ensures optimal tire wear and provides stable handling for the vehicle.You state that each inner tie rod is comprised of a ball pin, inner tie rod socket, and ball seat. The ball pin ismanufactured in Korea with the steel wire rod from China. In Korea, the wire rods undergo descaling;downstream processes: such as drawing, heat treatment, and cold forging; heat treatment (annealing) andcoating. The rod is then subject to head upsetting, head forming, forward extrusion, hex extrusion, crackinspection, screw thread rolling, zinc-nickel plating, groove machining, and ball section turning andburnishing. The product is then assembled together with the inner tie rod socket of Chinese origin and a ballseat, which you purchase from another supplier in Korea.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unlessexcepted, every article of foreign origin imported into the United States shall be marked in a conspicuousplace as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such amanner as to indicate to the ultimate purchaser in the United States, the English name of the country of originof the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should beable to know by an inspection of the marking on the imported goods the country of which the goods is theproduct. 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 shouldinfluence 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 thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, orgrowth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.In the present case, the major component that imparts the character of the inner tie rod is the ball pin. It issubstantially transformed from a wire rod into an identifiable ball pin in Korea. As such, the substantialtransformation occurs in Korea and the Chinese components lose their individual identities and become partsof the inner tie rods when affixed onto the unit. As a result, the country of origin of the inner tie rods, PartNumbers 38220013/RIT0562 and 38010480/RIT0585, will be South Korea for marking purposes and traderemedies under Section 301, as amended, from China will not apply.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Liana Alvarez at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division