The country of origin of a fire rake

N350599 June 27, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a fire rake Dear Mr. Jin: In your letter dated June 25, 2025, you requested a country of origin determination for purposes of Section 301 and IEEPA duties. Pictures of the merchandise in different stages of manufacture were included with your submission, along with a narrative of the manufacturing processes. The item under consideration is a fire rake. It is a hand tool used for digging trenches, clearing underbrush, and creating fire breaks. The tool consists of a double-sided head connected to a fiberglass handle. One side of the head is a hoe blade and the other side is a rake with six tines. The manufacturing process for the fire rake begins in Vietnam, where raw steel is laser-cut into the final shape of the double-sided rake head. This includes the six tines of the rake and the hoe blade. The fully formed rake head is then sent to China where it is riveted and welded to a connection point that accommodates the handle. Finally, the rake head and connection point are powder coated and assembled with a fiberglass handle. When determining the country of origin for purposes of applying current trade remedies under Section 301 and other duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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). Regarding the fire rake, it is our view that raw steel is substantially transformed in Vietnam into the fully formed double-sided rake head. It is the rake head that provides the principal characteristics of the finished fire rake, is dedicated for use as such, and cannot be used for any other purpose. Based on the provided descriptions and pictures of the additional processing and assembly operations performed in China, the rake head is not substantially changed so as to transform it into a new article with a different name, character, or use. It is therefore the opinion of this office that the country of origin of the fire rake 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, (for) Steven A. Mack Director National Commodity Specialist Division