RE: The country of origin of a strut 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 N364865 October 1, 2026 OT:RR:NC:N:206 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a strut assembly Dear Ms. Murrin: In your letter dated September 4, 2026, you requested a country of origin ruling on a complete strut assembly on behalf of your client Jinbo Auto Parts (Thailand) Co., Ltd. The article under consideration is a complete strut assembly (CSA), Part Number S0143-A0011, designed for use on Ford-150 (2004-2008) and Lincoln Mark LT (2006-2008). The CSA is a primary automotive suspension component, combining a coil spring and a shock absorber (strut) into a single integrated unit. It is installed on the front axle of vehicles with independent suspension setups. Its function is to bear vehicle weight, absorb vertical road impacts and vibrations, maintain tire contact with the road surface, and provide vehicle stability and passenger comfort. The CSA consists of a coil spring, strut, mounts, bumpers, and dust cover. The manufacturing processes and final assembly occurs in Thailand. In Thailand, the raw material and purchased components from China are received and inspected. The bottom cover is press-fitted onto the outer/reservoir tube using a high-precision press machine, followed by press forming to the required dimensions, and welded. The welded assemblies undergo 100% leak testing to detect microscopic weld failures. Following the assembly, the inner walls of the tubes undergo multi-stage ultrasonic cleaning to remove all particles and contaminants. The completed outer reservoir tube is assembled with related housing components to form the reservoir tube sub-assembly. The base valve assembly is a sub-assembly comprising multiple discs, washers, valves, seals, and rings assembled and riveted together in a precise sequence. The piston rod, manufactured from raw round steel through CNC machining, tapping, drilling, boring, and grinding, is assembled with multiple components to create a functional piston rod assembly: A rebound limit ring is precision-welded to the piston rod. The welded rod undergoes multi-stage ultrasonic cleaning to remove weld residue and particles that could damage seals. The loading guider sub-assembly is pressed onto the piston rod. The oil seal is lubricated and installed onto the rod.
The rod valve pack is assembled onto the rod following the same critical sequencing as the base valve assembly. A specialty locking nut is torqued to a precise specification; incorrect torque results in poor damping performance and testing failure. Nuts are punch-deformed to permanently secure the valve pack and prevent slippage. The piston rod is transformed from a machined steel rod into a functional suspension sub-assembly through welding, cleaning, assembly, torquing, and locking. The reservoir tube sub-assembly is filled with precisely specified absorber oil using an automated oil injection machine, and the piston rod assembly is inserted. Oil specification is critical to damping performance: different viscosity grades affect compression and rebound response, temperature tolerance, and seal longevity. After oil filling, the guide is pre-tightened to set the correct compression force on the oil seal. The assembled unit then undergoes 100% damping force testing to verify performance against specifications. The outer tube is then sealed by flanging, permanently enclosing the internal assembly. Finally, nitrogen is charged into the sealed unit. Nitrogen charging prevents hydraulic fluid foaming, resulting in more consistent and durable suspension control. The result is a completed bare shock absorber. The completed bare shock absorber is loaded onto an automated painting line, spray-painted for corrosion protection and finishing. Following that, the dust cover and dust shield are installed to protect the piston rod. Then, the anti-collision pad is installed to buffer at maximum compression, followed by the ring and ring bushing. Finally, the coil spring and upper/lower spring bumpers are installed using a coil spring press machine, and the strut mount and spring disc are installed and secured with top nuts torqued to specification. The finished CSA is labeled and packaged per customer specifications, and the finished goods are then transferred to inventory 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 New York Ruling (NYR) N307541, dated December 11, 2019, and NYR N309148, dated February 4, 2020, which was later affirmed by Headquarters Ruling (HQ) H310543, dated January 7, 2022, this office discussed a suspension strut of a similar construction as the CSA in your request. In this ruling, we determined that the shock absorber was the character of the entire strut assembly. In the present case, the shock absorber, as well as the rest of the strut assembly, is composed of various components from Thailand and China. This office could not identify a single component or a set of components from a single country that imparts the character of either the shock absorber or the entire assembly. In HQ H327997, dated Apr. 10, 2023, we stated that “[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.” Since the final assembly occurs in Thailand, the country of origin of the CSA, Part Number S0143-A0011, 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