The country of origin of a steering knuckle assembly

N362928
July 22, 2026
OT:RR:NC:N2:206
CATEGORY: Origin John Kenkel International Trade Law Counselors, PLLC 8647 Richmond Hwy, Suite 623 Alexandria, VA 22309 RE: The country of origin of a steering knuckle assembly Dear Mr. Kenkel: In your letter dated July 7, 2026, you requested a country of origin ruling on a steering knuckle assembly, filed on behalf of Viet Nam Haiya Technology Co., Ltd. The article under consideration has been identified as a steering knuckle assembly, Part Number HYA1448-2 (Customer Part Number LK004), which is used in motor vehicles. It is sometimes commercially referred to as a loaded knuckle. The knuckle is an automotive chassis component linking the front wheel hub, suspension and steering systems. It is installed on the inner side of the front wheels at both ends of the front axle to realize wheel steering and vertical suspension travel. It serves as the connecting point between tie rods, control arms, and braking components. The finished assembly consists of a steering knuckle, wheel bearing, flange, and a standard hardware kit. The steering knuckle blank, is an unfinished, raw piece of metal sourced from China, that is intended for further processing in Vietnam. You state that 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 Vietnam where it undergoes significant machining operations, including turning, milling, drilling, grinding, and finishing to produce a functional steering knuckle body. The wheel hub assembly is entirely forged, machined, and assembled in Vietnam through a complex process that involves forging ring materials into upper flange outer ring banks and upper flange inner ring blanks. The product then 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. The hardware kits are prepared in Vietnam and include bolts, nuts, shims, and bushings but sometimes vary depending on the components from car makers.

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. 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). Based on the totality of the manufacturing operations described, we find that the processing performed in Vietnam constitutes a substantial transformation of the imported components. Accordingly, the country of origin of the steering knuckle assembly, Part Number HYA1448-2, will be Vietnam. 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