The country of origin of drywall corner tools and a tape knife

N350796 July 7, 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 drywall corner tools and a tape knife 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 items under consideration are drywall corner tools and a tape knife. Drywall corner tools are hand tools designed to help with the application of joint compound and tape in the corners of drywall installations, creating a smooth and clean finish. They are used for both inside and outside corners and can also be used with other plastering materials such as stucco and concrete. You state that the steel blade of the outside drywall tool is 5 inches x 3-7/8 inches, and the steel blade of the inside drywall tool is 3-1/2 inches x 2-3/8 inches. They are attached to steel handles with polypropylene and thermoplastic rubber grips. A tape knife, also referred to as a taping knife, is a drywall tool with a wide, flexible steel blade used for applying and smoothing joint compound over drywall seams, screw or nail indentations, and other imperfections. You state that the blade of the imported tape knife will vary in sizes from 6 inches to 14 inches. It is attached to polypropylene and thermoplastic rubber handles. The manufacturing process for the drywall corner tools begins in Vietnam, where stainless steel is die cut into the rectangular and trapezoidal flat shapes of the blades. The blades are also stamped into their final angled forms before being sent to China. In China, each blade is welded together with a steel connection part and a Chinese-origin cold forged steel handle. Finally, polypropylene and thermoplastic rubber are applied to the steel handles in China. You propose the following two manufacturing scenarios for the taping knife: Scenario one: In Vietnam, stainless steel is die cut into flat trapezoidal shapes, which is the final size and shape of each blade. The blades are then sent to China where each is pressed together with a Chinese-origin aluminum rigid black plate. Holes are punched through the back plate and blade, and a polypropylene and thermoplastic rubber handle is attached. Finally, a zinc alloy hammer end is attached to the end of the handle. Scenario two: This scenario is the same as the first, except the aluminum rigid back plates are manufactured in Vietnam. The blades and back plates are then sent to China where they are pressed together. Holes are punched through the back plate and blade, and a polypropylene and thermoplastic rubber handle is attached. Finally, a zinc alloy hammer end is attached to the end of the 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 drywall corner tools and tape knife, it is our view that a substantial transformation occurs in Vietnam. It is here that steel is die cut into the final size and shape of the blade for each tool. In this case, it is the blade of each tool that contributes to the main functionality of each of the finished tools. Based on the provided descriptions and pictures of the additional processing and assembly operations performed in China, the blade 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 drywall corner tools and a tape knife in your proposed manufacturing scenarios 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