The country of origin of a utility knife from Vietnam.

N350719 July 16, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a utility knife from Vietnam. Dear Ms. Jin: In your letter dated June 27, 2025, you requested a country of origin ruling. The product under consideration is a utility knife that features an aluminum handle and a replaceable, disposable steel blade that is retractable into the handle using a sliding control knob. You indicate in your submission that these blades are not permanently attached to the handle. The knife allows the blade to be locked into three different positions and includes three extra utility blades stored in the handle. In your submission, you state this request is similar to the one in New York ruling N308152, dated December 18, 2019, except in this scenario, both the blade and handle body are produced in Vietnam as detailed below. In Vietnam, raw aluminum blocks from Vietnam, or potentially a different country including China, are diecast to make the left and right sides of the utility knife’s handle body. They are drilled and formed into their final shape and will be ready for assembly. In China, they are polished, powder coat painted, and assembled using small Chinese origin parts including a blade holder, metal switch, and a polyvinyl chloride (“PVC”) grip. The trapezoidal utility blade is punched into strips of blade blanks from raw steel in Vietnam. The strips of blades are heated treated in Vietnam and then sharpened in Vietnam. Finally, the sharpened blades are divided from the strips into individual blades in Vietnam before shipment to China. In China, the blades undergo a surface treatment and are then assembled with the blade holder. 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 order to determine whether a substantial transformation occurs when components 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/manufacturing operations that are minimal will generally not result in a substantial transformation. We find that together the handle and blade hold the essential identity of the finished utility knife and that they are not substantially transformed to become new articles having a new name, character, or use after being further processed in China. As such, we hold the opinion that the country of origin for this utility knife would be 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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division