The country of origin of a four-way crimp tool

N350766 July 9, 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 four-way crimp tool Dear Mr. Jin: In your letter dated June 30, 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 four-way crimp tool. It is a hand tool designed to secure electrical connectors onto wires by deforming the connector around the wire. The tool works by applying pressure from four different directions simultaneously, ensuring even crimping and a secure grip. It consists of two hinged handles and two round jaws that each incorporate a round hole. The jaws are assembled, one inside the other, with four steel cam-actuated indenters. The manufacturing process for the 4-way crimp tool begins in Vietnam, where carbon steel is forged into the final size and shape of the left handle and jaw. Also in Vietnam, the right handle and jaw is cut from steel and formed into its final size and shape. These two pieces are then sent to China, where they undergo precision milling and surface treatment, and a PVC grip is applied to each handle. Finally, the jaws and handles are assembled, one inside the other, with springs, rivets and four steel cam-actuated indenters. 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 four-way crimp tool, it is our view that a substantial a transformation occurs in Vietnam. It is here that steel is cut, formed and forged into the final size and shape of the left and right jaws and handles of the tool. It is these components that contribute to the main functionality of the finished tool, which is to apply pressure and force to a connector and wires. Based on the provided descriptions and pictures of the additional processing and assembly operations performed in China, these components are not substantially changed so as to transform them 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 four-way crimp 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, (for) James Forkan Acting Director National Commodity Specialist Division