The country of origin of a combination square

N351958 August 12, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC. 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a combination square Dear Mr. Jin: In your letter dated August 3, 2025, you requested a country of origin ruling on combination square. Descriptive literature was provided for our review. The item under consideration is described as a combination square, which is a measuring tool mainly consisting of a ruler and a square. It is widely used in woodworking, furniture making, and construction and allows precise length measurements, 45-degree and 90-degree angle marking, quick line drawing, depth and height measurements, and horizontal and vertical alignment. Additionally, the built-in bubble level helps craftsmen to align components. The 12-inch ruler features a dual-sided metric and Society of Automotive Engineers SAE markings with precision up to 1/16 inch and 1/32 inch. Furthermore, loosening the screw also allows the ruler to be used separately. The ruler is made of stainless steel, and the square is made of zinc alloy. The size of the square is 4.33 inches by 3.54 inches, and the size of the ruler is 12 inches. The complete combination square weighs 11.6 ounces. The Vietnamese components include the square and the ruler, while the Chinese components include the bubble level, spring, adjustable screw and nut, bolt and plastic cap. In Vietnam, the Vietnamese sourced zinc alloy plate is die casted into the final size and shape of the square. Then the square is sent to China for further powder coating and machining. Concurrently, the Chinese sourced stainless-steel coil is cut to the size of the ruler, polished, and then sent to Vietnam, where the measurements are laser engraved. Then the ruler is sent to China for further groove plaining and finally the square and the ruler are assembled together with the small components (including bubble level, spring, screw, nut, bolt, etc.). When determining the country of origin, 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 origin of the combination square, it is our view that the device becomes a measuring device when substantially transformed in Vietnam by laser engraving the measurements onto the ruler. Additionally, the square is die casted in Vietnam which created the shape and character of the square. Once the ruler, with its engraved measurements and die cast square are sent to China for final processing they cannot be used for any other purpose than that of a measuring combination square. The simple combining of the small components in China does not transform the square and ruler into a new article with a different name, character, or use. Therefore, it is the opinion of this office that the country of origin of the combination square 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division