RE: The country of origin of an automotive carrier

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 N364411 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 carrier Dear Mr. Kwon: In your letter dated August 20, 2026, you requested a country of origin ruling on automotive carrier on behalf of Seohan Innobility Co., Ltd. The article under consideration is identified as the TM PE Carrier LH, part number M52715-S1AA0, which is designed for use in the rear suspension system of the TM PE vehicle model. The carrier provides mounting points for various suspension, steering, braking, and wheel-speed detection components, including the lower arm, upper arm, assist arm, trailing arm, constant velocity joint, wheel speed sensor, and brake caliper. The carrier also supports the rear wheel load of the vehicle. According to the information provided, the TM PE Carrier LG is manufactured in South Korea from aluminum ingot, aluminum scrap, strontium, and magnesium of Chinese origin. In South Korea, the aluminum ingot and scrap are melted and combined with the strontium and magnesium additives. The molten aluminum undergoes modification and degassing treatments before being subjected to an electromagnetic-stirring high-pressure casting process. During the casting operation, the prepared aluminum is formed into the specifically shaped TM PE Carrier LH. The casting is subsequently cooled, trimmed to remove the gates and excess material, and heat treated. The completed carrier then undergoes visual and X-ray inspections before being packaged for shipment. 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 materials imported into South Korea consist of Chinese-origin aluminum ingot, aluminum scrap, and alloying additives. At the time of their importation into South Korea, these materials do not possess the name, shape, character, or dedicated use of an automotive carrier. In South Korea, the materials are melted, combined, treated, and subjected to an electromagnetic-stirring high-pressure casting operation that forms the aluminum into the specifically shaped TM PE Carrier LH, part number M52715-S1AA0. Through these operations, the raw materials acquire the physical configuration and predetermined use of a dedicated rear suspension component. 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 TM PE Carrier LH, part number M52715-S1AA0. Accordingly, the country of origin 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