The country of origin of a pocket knife from Vietnam.

N350962 July 30, 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 pocket knife from Vietnam. Dear Ms. Jin: In your letter dated July 7, 2025, you requested a country of origin ruling on a multi-function pocket knife. The product under consideration is a pocket knife that features 11 functions, including: a drop point blade, small flathead screwdriver, can opener, spring action scissors, wire stripper, bottle opener, large flathead screwdriver, tweezers, toothpick, awl with thread loop, and a Phillips head screwdriver. The blade is stainless steel, and the handle is made with G10 material. In your submission, you indicate there are two production scenarios. Scenario 1 In Vietnam, the stainless steel sourced from Vietnam, or potentially a different country, is cut into the final size and shape of the knife blade. The blade blank is then sent to China for further heat treatment, polishing, surface treatment, and sharpening. In China, the other elements including the handles, the other function parts, and the small items used in assembly are produced and assembled with the Vietnamese blade to form the finished pocket knife. Scenario 2 In Vietnam, the stainless steel sourced from Vietnam, or potentially a different country, is cut into the final size and shape of the knife blade, along with the other function parts. Then these metal components are sent to China for further machining, heat treatment, polishing, surface treatment, and sharpening. In China, the other elements including the handles and the small items used in assembly are produced and assembled with the Vietnamese blade and function parts to form the finished pocket knife. 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 the folding knife blade provides the essential identity to the finished pocket knife and that it is not substantially transformed to become a new article 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 multi-function pocket knife, under both scenarios, 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