RE: The country of origin of a steering knuckle

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 N364783 September 22, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Aaron Marx Crowell & Moring, LLP 600 Fifth St. NW Washington, DC 20901 RE: The country of origin of a steering knuckle Dear Mr. Marx: In your letter dated September 2, 2026, you requested a country of origin ruling of a steering knuckle on behalf of Q-Thai Parts Co., Ltd. The item is a steering knuckle assembly, model 10801138BP1JT, which you describe as a critical structural component used in automotive steering, suspension, and wheel-end systems. It provides wheel support, steering positioning, wheel rotation, and mounting interface for the braking components, and contributes to vehicle safety, handling stability, and reliability during vehicle operation. The assembly consists of a steering knuckle, wheel hub bearing assembly, and other minor components. You state that the steering knuckle is produced entirely in Thailand from sand, pig iron, and other raw materials. The process starts with the casting of the knuckle by sand mixing, molding, melting, automatic pouring, shot blasting, and automating grinding. Then, the knuckle undergoes electrophoretic coating, computer numerical control (CNC) machining of the bearing bore and dust shield hole, and precision machining. After that, the knuckle is assembled with the dust shield, bearing, snap ring, seal, and wheel hub, which are imported from China. Finally, the product is tested, laser marked, quality checked, and packaged for shipping. 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). This office reviewed a similar scenario in ruling N360457, dated May 6, 2026. In that ruling we stated that the knuckle and wheel hub are equally essential components of a steering knuckle assembly. We then cited
Headquarters ruling HQ H327997, dated Apr. 10, 2023, which stated “[i]n instances in which component production or assembly occurs in multiple countries and no single country’s operations dominate the manufacturing operations, CBP has looked to the location at which final assembly occurs.” Similarly, in the instant scenario, the steering knuckle is produced in Thailand, while the wheel hub assembly is imported from China. Since the final assembly occurs in Thailand, the country of origin of the steering knuckle assembly, model 10801138BP1JT, will be Thailand. 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