The country of origin of chassis components

N362462
July 14, 2026
OT:RR:NC:N2:206
CATEGORY: Origin Nora Zeng Vietnam Four Season Machinery Manufactory Company Limited Lot CN3D, Deep C 2B Industrial Park, Dinh Vu - Cat Hai Economic Zone Hai Phong 180000 Vietnam RE: The country of origin of chassis components Dear Ms. Zeng: In your letter dated June 20, 2026, you requested a country of origin ruling on chassis components. The articles under consideration are a ball joint (bolt-on), Part Number WGHBJ-007, stabilizer, Part Number WGHLG-0492, ball joint (press-in), Part Number WGHQT-0344, tie rod end, Part Number WGHLG-0544, and sway bar link, Part Number WGHLG-0738, which you refer to as chassis components. You state that these components connect the body to the wheels, ensuring stability, handling, and comfort. These articles are core components of a suspension and steering system and serve as the direct connection points between the front wheel assemblies and the vehicle's frame. According to the bills of materials (BOMs) submitted with your request for each product, Parts WGHBJ-007, WGHLG-0492, and WGHQT-0344 each contain a Vietnamese ball socket and packaging, as well as a Chinese nut, ball stud, ball seat, lubricant grease, and clips. PartsWGHLG-0544 and WGHLG-0738 each contain a Vietnamese ball socket, dust cover, seal plate, and packaging, and a Chinese ball stud, ball seat, lubricant grease, and clips. The Chinese subparts are imported into Vietnam, where they are assembled with the Vietnamese subparts. 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. 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 the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 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). Assembling the subparts together to create the finished chassis components does not result in a substantial transformation. As a result, we look to the character of each product to determine the country of origin. In multiple rulings, we determined that the character of ball joints, tie rods, and sway bar links is the ball stud (ball pin) and ball socket (housing). See N347758, dated 05/08/2025, for ball joints; N352155, dated 08/28/2025 and N360321, dated 04/23/2026, for tie rods; and N346637, dated 04/02/2025, for sway bar links. In this case, the ball studs are sourced from China, while the ball sockets are made in Vietnam. Considering that the final assembly of all subparts occurs in Vietnam and the value of Vietnamese parts and labor is higher than the value of the Chinese parts, the country of origin of the ball joint (bolt-on), Part Number WGHBJ-007, ball joint (press-in), Part Number WGHQT-0344, tie rod end, Part Number WGHLG-0544, and sway bar link, Part Number WGHLG-0738, will be Vietnam. However, Part WGHLG-0492 is different from the stabilizers we have previously ruled on. Part WGHLG-0492 is constructed of a ball stud, which represents the product’s entire body. The Vietnamese socket does not impart the character of the stabilizer. As a result, it is the opinion of this office that the Chinese ball stud is the character of the product and the country of origin of the stabilizer, Part Number WGHLG-0492, 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