The country of origin of a Cable and Wire Stripper Tool

N341088 July 16, 2024 OT:RR:NC:N1:118 CATEGORY: Origin M Jason Cunningham Sonnenberg & Cunningham PA 780 Fifth Ave. South, Suite 200Naples, FL 34102 RE:  The country of origin of a Cable and Wire Stripper Tool Dear Mr. Cunningham: In your letter dated July 3, 2024, on behalf of your client, Great Star Industrial USA, LLC, you requested a ruling on the country of origin of a Cable and Wire Stripper Tool that is manufactured in China and Vietnam.  Pictures of the tool in different stages of manufacture were included with your submission. The hand tool under consideration is commonly and commercially known as a self-adjusting wire stripper.  This tool allows the user to strip various sizes and types of wire.  The grasping and cutting parts of the jaws of the hand tool automatically adjust to the size of wire and strip the wire’s coating to expose the inner wire or wires.  The user can adjust the amount of tension for more precise adjustment by twisting a knob on the jaws.  The handles of the Cable and Wire Stripper Tool add additional functionality of wire cutting and crimping. The manufacturing process for the tool begins in Vietnam, where raw steel is precisely die cut into the left and right handles and jaws.  Also in Vietnam, raw aluminum is diecast into the holding and stripping parts of the tool’s jaws.  The parts made in Vietnam have their final shape, size, and form.  The fully formed handles and jaws are then sent to China where they are painted and assembled with minor parts, including pins, springs, clips, screws, bolts, and plastic handle covers.  The finished Cable and Wire Stripper Tool is then shipped to the United States. Regarding your request for the appropriate country of origin for the finished Cable and Wire Stripper Tool, 19 C.F.R. § 134.1(b) provides in pertinent part as follows: Country of origin means 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 this part; 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, 69 C.C.P.A. 151 (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 order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character and use has been produced.  No one factor is decisive, and assembly operations that are minimal will generally not result in a substantial transformation.  In regard to the Cable and Wire Stripper Tool, we find that the processes and assembly operations performed in China do not constitute a substantial transformation of the two main components of the tool (i.e., the handles and jaws) that are manufactured in Vietnam.  These articles provide the principal characteristics of the finished tool, are dedicated for use as such, and cannot be used for any other purpose.  The character of the handle and jaws remains unchanged after the painting and minor assembly that occurs in China.  Therefore, it is the opinion of our office that the country of origin of the finished Cable and Wire Stripper Tool is Vietnam. 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 Anthony Grossi at anthony.e.grossi@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division