N352155

N352155 August 28, 2025 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification; Origin TARIFF NO.: 8708.94.7550; 9903.94.05; 9903.01.33 John Kenkel International Trade Law Counselors, PLLC 8647 Richmond Hwy, Suite 623 Alexandria, VA 22309 RE: The tariff classification and country of origin of inner and outer tie rods Dear Mr. Kenkel: In your letter dated August 7, 2025, you requested a tariff classification and country of origin determination ruling on inner and outer tie rods, which you filed on behalf of GAA Automotive Technology Sdn Bhd. The articles under consideration are Inner Tie Rods (Models D-40122 and D-40179) and Outer Tie Rods (Models L-3315J, L-2050J, and L-2860J), which are used in passenger vehicles. The inner tie rods are parts of the automobile steering mechanism, which directly affect the stability of the automobile handling, safety of operation and service life of the tires. The inner tie rods are responsible for transmitting the movement of the steering rocker arm to the steering knuckle arm; they also ensure the correct movement relationship between the left and right steering wheels. The inner tie rod sub-assemblies include ball pin, ball socket and other accessories. One end of a single tie rod is connected to the tie rod ball head, and the other end is connected to the steering gear to achieve accurate steering control. The outer tie rods are often used in conjunction with inner tie rods, with one end connected to the tire. They can achieve precise steering of the car, making the car run more smoothly and accurately. As key components connecting the suspension and the stabilizer bar, the outer tie rods are mainly responsible for the transmission of force between the vehicle suspension and the stabilizer bar. They can effectively ensure the stability and balance of the suspension system during driving, thereby improving the vehicle's handling performance. The outer tie rod sub-assemblies include boot, bushing, ball pin, ball socket, backing plate and other accessories. You state that the housing and the ball pin of the inner tie rods are sourced from Malaysia, while the clip, ball socket, nut, gaskets, brackets, and cable ties are sourced from China and imported into Malaysia to be assembled to create the complete inner tie rods. The outer tie rods are also assembled in Malaysia from the boot, housing, and ball pin from Malaysia, and the nut, bolt, spiral ring clips, ball socket, backing plate, glib, and gasket from China. You suggest that the inner and outer tie rods be classified in subheading 8708.80.1600, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705:Other parts and accessories: Other: Other: Other: Other: Suspension systems and parts thereof (including shock absorbers): Parts: Other.” We disagree. The inner and outer tie rods are neither suspension systems nor parts of suspension systems. They connect the steering rack to the wheels. As a result, they are better described as steering parts than suspension parts. The applicable subheading for the Inner Tie Rods (Models D-40122 and D-40179) and Outer Tie Rods (Models L-3315J, L-2050J, and L-2860J) will be 8708.94.7550, HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Steering wheels, steering columns and steering boxes; parts thereof: Parts: For other vehicles: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. 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 assembly process described for the inner and outer tie rods do not appear to be complex enough to render a substantial transformation. None of the components transform into a new article after being turned, laser marked, greased, pressed into one another, tested, and packaged in Malaysia. Thus, we look to the country of origin of the major components of each tie rod assembly. It is the opinion of this office that the housings and ball pins in both assemblies impart the character of the inner and outer tie rods. Therefore, the country of origin for the Inner Tie Rods (Models D-40122 and D-40179) and Outer Tie Rods (Models L-3315J, L-2050J, and L-2860J) will be Malaysia. Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading 8708.94.7550, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Malaysia will be subject to an additional ad valorem rate of duty of 19 percent. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.33, in addition to subheading 8708.94.7550, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. 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 liana.alvarez@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division

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 assembly process described for the inner and outer tie rods do not appear to be complex enough to render a substantial transformation. None of the components transform into a new article after being turned, laser marked, greased, pressed into one another, tested, and packaged in Malaysia. Thus, we look to the country of origin of the major components of each tie rod assembly. It is the opinion of this office that the housings and ball pins in both assemblies impart the character of the inner and outer tie rods. Therefore, the country of origin for the Inner Tie Rods (Models D-40122 and D-40179) and Outer Tie Rods (Models L-3315J, L-2050J, and L-2860J) will be Malaysia. Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading 8708.94.7550, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, product