The country of origin of a 4-way cross wrench

N350720 July 2, 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 4-way cross wrench Dear Mr. Jin: In your letter dated June 27, 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 identified as a 4-way cross wrench, also referred to as a 4-way lug wrench. It is a steel hand tool used to loosen, tighten, or remove lug nuts on wheels. The tool is designed in a cross-like shape with four different socket sizes on its ends. Each cross bar measures 20 inches long and the four ends incorporate 11/16-inch, 3/4-inch, 13/16-inch, and 7/8-inch hexagonal socket sizes. The manufacturing process for the 4-way cross wrench begins in Vietnam, where carbon steel is cut into the two cross bars of the wrench. The final sizes of the hexagonal sockets are then hot stamped into the ends of each bar. The two cross bars are sent to China, where they are further milled, engraved with the socket measurements, heat-treated and polished. Finally, the cross bars are welded together at their center and powder coated. 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 4-way cross wrench, it is our view that carbon steel is substantially transformed in Vietnam into the two 20 inch long cross bars of the wrench, along with the final shape and size of the four hexagonal socket ends. These two bars, with the socket ends, provide the principal characteristics of the finished 4-way cross wrench, are 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 4-way cross wrench 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 4-way cross wrench 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) James Forkan Acting Director National Commodity Specialist Division