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 N364410 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 MV/ME Knuckle Assembly, part number 51710-DO000. The subject knuckle assembly is a component of a motor vehicle’s front suspension system. It 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 knuckle assembly consists primarily of the MV/ME Cast Knuckle, part number M51715-DO000, and two sockets that are 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. In South Korea, these materials undergo melting, tapping, degassing, casting, trimming, cutting, finishing/deburring, heat treatment, X-ray inspection, and packaging. Through these operations, the Chinese-origin materials are formed into the specifically shaped MV/ME Cast Knuckle, part number M51715-DO000. The cast knuckle is subsequently supplied to another manufacturer in South Korea, where it undergoes two stages of machining. The machining operations include facing, boring, drilling, rapping, counterboring, milling, and chamfering of various reference faces, mounting holes, seating faces, and other features
associated with the brake caliper, control arms, ABS sensor, and other components. Following the machining operations, dockets are press-fit into the T/Arm and L/Arm mounting locations. The completed article is then inspected and supplied as the MV/ME Knuckle Assembly, part number 51710-DO000. 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). The circumstances presented in this instance are distinguishable from situations in which a recognizable and dedicated casting is imported into another country for subsequent machining and finishing. In this case, the materials imported from China into South Korea consist of aluminum ingot, aluminum scrap intended for remelting, aluminum-strontium allot, and magnesium. At the time of their importation into South Korea, these materials do not possess the name, shape, character, or dedicated use of an automotive knuckle. Instead, it is in South Korea that the Chinese-origin materials are melted and processed and then cast into the specifically shaped M51715-DO000 knuckle. The Korean casting operation imparts the article with the basic physical configuration and dedicated automotive use of a knuckle, including the structure from which the various suspension, steering, and braking mounting features are subsequently machined. Accordingly, the casting operation results in a distinct article of commerce having a new name, character, and use different from the Chinese-origin materials from which is was produced. 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 MV/ME Knuckle, part number M51715-DO000. Accordingly, the country of origin of the finished MV/ME Knuckle Assembly, part number 51710-DO000, 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