RE: The country of origin of an automotive knuckle assembly

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 N364409 September 1, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Jiwon Kwon Cusan Customs Service Incorporation 309, 35, Magokjungang 2-ro, Gangseo-gu, Seoul 07806 South Korea RE: The country of origin of an automotive knuckle assembly Dear Mr. Kwon: In your letter dated August 20, 2026, you requested a country of origin ruling on an automotive knuckle assembly on behalf of Seohan Innobility Co., Ltd. The article under consideration is identified as the LX3 Knuckle Assembly, part number 51710-P9000, which is designed for use in the front suspension system of certain motor vehicles. The knuckle assembly provides mounting points for the shock absorber, lower control arm, tie rod, constant velocity (CV) joint, wheel speed sensor, brake caliper, and wheel. The assembly supports the front wheel load and facilitates functions associated with steering, braking, wheel speed detection, and shock absorption. The finished LX3 Knuckle Assembly consists primarily of an aluminum LX3 Cast Knuckle, part number M51715-P000, and a socket, part number 51798-3M100, that is press-fit into the knuckle. The cast knuckle provides the principal structure of the finished assembly and the mounting locations for the various suspension, steering, braking, and wheel-related components. According to the information submitted, the manufacturing process begins with Chinese-origin aluminum ingot, aluminum scrap, aluminum-strontium alloy, and magnesium. The aluminum is imported into South Korea in ingot block form, while the aluminum scrap consists of defective products and gate/runner cut-off scrap intended for remelting. The aluminum-strontium alloy is imported in round-bar form, and the magnesium is imported in small ingot or block form. The prepared molten aluminum is subjected to an electro-stirring high-pressure casting process. During this operation, the molten aluminum is introduced into a dedicated casting mold and solidified into the shape of the LX3 Cast Knuckle. Following casting, the article is cooled and undergoes trimming and gate/runner cutting to remove excess material. The cast knuckle is then heat treated and subjected to visual and X-ray inspections. The LX3 Cast Knuckle subsequently undergoes several precision machining operations using three-axis and four-axis machining centers. These operations include machining the datum face and step, bore, cover, for-hole locations, and caliper features. Additional machining is performed on the U-arm, T-arm, L-arm, and
ABS features and includes cutting, drilling, boring, reaming, chamfering, and tapping operations. The machined knuckle is inspected using various gauges to verify the required dimensions, positions, and tolerances. The socket, part number 51798-3M100, is of Korean origin and is sourced from a Korean supplier. Following completion of the machining operations, the socket is press-fit into the machined knuckle. The completed article undergoes final inspection and becomes the LX3 Knuckle Assembly, part number 51710-P9000. 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 instant case, the Chinese-origin materials imported into South Korea consist of aluminum ingot, aluminum scrap, and alloying additives. At the time of importation into South Korea, these materials do not posses the name, character, or dedicated use of an automotive knuckle. It is in South Korea where the materials are melted, alloyed, treated, and subjected to a high-pressure casting operation using a dedicated mold. As a result of this process, the raw materials are formed into the LX3 Cast Knuckle, and article possessing the basic shape and predetermined use of the automotive knuckle incorporated into the finished assembly. This conclusion is also consistent with NY N301439, dated November 21, 2018, in which foreign-origin aluminum materials were melted and processed in South Korea to produce aluminum billets. CBP determined that the processing performed in South Korea substantially transformed the foreign-origin materials and that the resulting billets were products of South Korea. Based on the totality of the circumstances, we find that the Chinese-origin materials undergo a substantial transformation in South Korea when they are processed and cast into the LX3 Cast Knuckle, part number M51715-P000. Accordingly, the country of origin of the finished LX3 Knuckle Assembly, part number 51710-P9000, is South 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