RE: The country of origin of a constant velocity joint subassembly

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364156 August 25, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Sa Ung Kim SEIN Customs & Auditing Corp 138, Seoun-ro, Seocho-gu Seoul 06619 Korea, South RE: The country of origin of a constant velocity joint subassembly Dear Mr. Kim: In your letter dated August 10, 2026, you requested a country of origin ruling on a constant velocity joint subassembly. The merchandise under consideration is a spherical-type constant velocity (“CV”) joint sub-assembly (Product No. 8107156), designed for incorporation into an automotive drive shaft. The subassembly consists of an outer race, inner race, cage, and balls, all constructed of carbon steel. The subject CV joint subassembly measures approximately 163.6 mm by 106 mm by 106 mm and weighs approximately 2.166 kilograms. A drive shaft transfers rotational force from the vehicle’s transmission to the drive wheels. The subject CV joint subassembly is incorporated into the drive shaft and allows rotational force to be transmitted at a constant angular velocity while accommodating changes in the angle of the drive shaft resulting from steering and suspension movement. The outer and inner races contain precision raceways, or ball tracks, along which the balls travel. The cage maintains and guides the balls at specified intervals. You state that the raceways formed in the outer and inner races are critical to the function and performance of the CV joint because they determine the rolling paths of the balls and significantly affect the transmission of rotational force. You propose two manufacturing scenarios. Scenario 1 Under scenario 1, the outer race begins as a carbon-steel round bar of Chinese origin. The round bar is exported to the Republic of Korea, where it undergoes cutting and heat treatment followed by hot forging, which forms the material into the required general shape of the outer race. Following forging, the outer race undergoes shot blasting and turning. A rolling operation forms the spline and ring groove on the shank. The outer race then undergoes ball-grove rough and finish machining, during which the precision raceways, or ball tracks, are formed through cutting operations. Additional heat treatment is performed to achieve the
required final hardness and wear resistance. Internal and external-diameter grinding establishes the final dimensional and geometric accuracy of the article, while ball-groove grinding achieves the final shape and surface accuracy of the raceways. The outer race is subsequently painted, cleaned, and inspected in Korea. The inner race is manufactured in China from Chinese-origin material. The cage and balls are manufactured in the Republic of Korea from Korean-origin material. The finished outer race, inner race, cage and balls are assembled in the Republic Korea to form the subject CV joint subassembly. The completed subassembly is inspected in Korea for rotational performance, operating angle, assembly condition, and other functional and quality requirements. Scenario 2 Under scenario 2, the manufacturing process differs with respect to the initial production of the outer race. A carbon-steel round bar of Chinese origin undergoes cutting and heating treatment in China. The material is then warm forged and cold sized in China to form the general shape of the outer race. The resulting semi-finished outer-race forging is exported to the Republic of Korea. In Korea, the semi-finished forging undergoes shot blasting and turning to further machine the article into the required product shape. Rolling operations form the spline and ring groove on the shank. Ball-groove rough and finish machining is then performed in Korea to form the precision raceways, or ball tracks, through cutting operations. The outer race subsequently undergoes heat treatment in Korea to achieve the required final hardness and wear resistance. Inter and external-diameter grinding establishes the final dimensional and geometric accuracy of the article. Ball-groove grinding is then performed to achieve the final shape and surface accuracy of the raceways. The outer race is subsequently painted, cleaned, and inspected in Korea. As in Scenario 1, the inner race is manufactured in China, while the cage and balls are manufactured in the Republic of Korea. The components are assembled in Korea to form the subject CV joint subassembly, which is then inspected for rotational performance, operating angle, assembly condition, and other functional and quality requirements. In both scenarios, the spline is formed on the outer race in Korea. 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). Under scenario 1, we find that the manufacturing operations performed in the Republic of Korea substantially transform the Chinese-origin round bar into a new and different article of commerce. The round bar enters Korea as raw material and emerges as a finished outer race possessing the physical and functional characteristics necessary for incorporation into the CV joint. Of particular significance, the precision raceways that are critical to the operation of the outer race are formed and finished in Korea. Considering the totality of the circumstances, including the extent of the manufacturing performed in Korea and the subsequent assembly of the outer race with the remaining components into the subject CV joint subassembly, we find that the country of origin under Scenario 1 is the Republic of Korea. Scenario 2 presents a closer question because the Chinese-origin material enters Korea as a semi-finished outer-race forging that is already dedicated for use in the finished article. However, as recognized in National Hand Tool Corp v. United States, predetermined use alone does not preclude a finding of substantial transformation, and the determination must be based on the totality of the evidence.
Unlike the components in National Hand Tool, which had already been formed into their final shape prior to the subsequent processing, the outer-race forging in Scenario 2 has not acquired its final functional characteristics when it enters Korea. Most significantly, the splining and precision raceways, or ball tracks, are formed and finished in Korea. The spline is a significant functional feature of the outer race because it permits the CV joint to engage with the drive shaft and transmit rotational force through the drivetrain. Thus, in addition to forming and finishing the precision raceways, the Korean processing imparts another feature necessary for the outer race to perform its intended power-transmission function. The raceways are critical to the function of the outer race because they provide the paths along which the balls travel and enable the CV joint to transmit rotational force while accommodating changes in the operating angle of the drive shaft. The additional Korean processing also imparts the final dimensional accuracy, hardness, and surface characteristics necessary for the outer race to perform its intended function. Therefore, based on the totality of the evidence, we find that the processing performed in Korea substantially transforms the semi-finished Chinese outer-race forging. Accordingly, the country of origin for the subject CV joint subassembly under Scenario 2 is the Republic of Korea. 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