N351425

N351425 July 29, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Roderick Bryant CTS Automotive Co., LTD. 505 Gerald Bryant Rd Guntersville, AL 35976 RE: The country of origin of a stabilizer link assembly. Correction to Ruling Number N350324 Dear Mr. Bryant: This replaces Ruling Number, N350324, dated July 10, 2025, which contained a clerical error. The company’s name in the address line was incorrectly listed as Zhejiang Ruitai Suspension System Technology Ltd. It has now been corrected to CTS Automotive Co., LTD. A complete corrected ruling follows. In your letter, dated June 17, 2025, you requested a country of origin ruling on a stabilizer link assembly. The article under consideration is a Stabilizer Link Assembly, Model Number SB-200, Part Number RLL84202, which is a component of an automotive suspension system. The stabilizer link connects the suspension system to the body for flexibility through joints and/or bushings to effectively absorb shocks and vibrations caused by uneven roads. The primary function of the link is to ensure that the tires maintain constant contact with the road, providing traction, stability, and control. The stabilizer link assembly consists of ball studs, a dust cover, bearing, protect cover, cover plate, nuts, and link housing, which is a rod with two eyelets. The stud blank from steel forging and a steel bar for the link housing are sourced from China and imported into Thailand for further processing. In Thailand, the stud blank undergoes machining, such as rough turning and finish turning of the ball head, shank, and undercut. Further, the stud is heat treated, degreased, water washed, pickled, water washed again, acidic activator treated, trivalent chromium plated, water washed again, passivated, water washed again, dried, and inspected. The steel bar for the link housing is machined by rough turning and fine turning of the two eyelets and link rod and welding the two housings and link rod together. After that, the link housing is E-coated by degreasing, water washing, hydrochloric acid, water washing again, rust prevention, and electrophoresis. Finally, the finished ball stud and link housing are combined together in Thailand with the rest of the components, which are all produced in China and imported to Thailand, by inserting and installing into each other to create the finished stabilizer link assembly. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In the present case, the main components of the stabilizer link, which are the ball stud and the link housing, are substantially transformed into new and different articles as a result of manufacturing processes in Thailand. The finished ball stud and link housing are then combined together in Thailand with the rest of the Chinese-origin components through operations that are not sufficiently complex in order to create the finished stabilizer link assembly. Because the ball stud and link housing, which have been substantially transformed in Thailand, impart the identity of the finished stabilizer link assembly, we find that the country of origin of the Stabilizer Link Assembly, Model Number SB-200, Part Number RLL84202, will be Thailand for marking purposes. 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 above, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division

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 above, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Acting Director National Commodity Specialist Division