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 N364787 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 on a steering knuckle. The article under consideration is an automotive steering knuckle, identified as model number 10801126JT. The steering knuckle is a structural component of a vehicle's steering and suspension systems, serving as a load-bearing link between the wheel assembly and the chassis. It facilitates wheel support, positioning, and steering. It also withstands the steering forces, braking forces, lateral forces, and road-induced impact loads generated during vehicle operation. The steering knuckle consists of a steering knuckle body manufactured in Thailand and three bushings manufactured in China. In Thailand, the steering knuckle body undergoes multiple manufacturing and finishing operations, including shot blasting, grinding, electrophoretic coating, and precision machining. The machining operations include matching the bearing mounting bore, precision machining of key mounting and functional surfaces, and machining the mounting holes for the dust shield. These operations establish the dimensions and functional surfaces necessary for the steering knuckle body to perform its intended function. Following the machining operations, the three Chinese-origin bushings are positioned at designated mounting locations and press-fit into the steering knuckle body using a hydraulic press. The completed assembly is then inspected and 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). Based on the information provided, the steering knuckle body manufactured and machined in Thailand imparts the character and primary function of the finished steering knuckle. The incorporation of the
Chinese-origin bushings does not substantially transform the Thai-origin steering knuckle body into a new and different article of commerce with a different name, character, or use. Rather, the bushings are incorporated into an already identifiable steering knuckle body whose essential structural and functional characteristics have been established through the manufacturing and machining operations performed in Thailand. Accordingly, we find that the country of origin of the subject steering knuckle, model 10801126JT, is 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