The country of origin of miter shears

N351961 August 11, 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 miter shears Dear Ms. Jin: In your letter dated August 4, 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 merchandise under consideration is identified as miter shears. The pair of shears is a hand-held tool used for cutting molding, trim, and other thin materials at precise angles for projects such as picture frame assembly or baseboard installations. The tool consists of a cutting head with two main parts: a cutting blade and a static anvil. The cutting head is attached to two spring-loaded metal handles with plastic grips. To operate the tool, the user places the material to be cut onto the anvil, which has markings to guide angled cuts at 0 degree, 22.5 degrees and 45 degrees. The handles are then pressed together to activate the blade and cut the material. The manufacturing process begins in Vietnam, where stainless steel plate is stamped into the final size and shape of the blade. A hole is also stamped into the blade for assembly purposes. Additionally in Vietnam, aluminum alloy is die cast into the final size and shape of the anvil. It is further cropped, deburred and the angle degrees are marked into it. The blade and anvil are then sent to China, where the blade is heat-treated and sharpened, and the anvil is shot blasted. Finally, the handles are stamped from carbon steel and are assembled with the blade, anvil, and plastic handle grips using screws, nuts, and other small Chinese-origin components. 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). In regard to the miter shears, it is our view that the blade and anvil hold the essential identity of the finished miter shears. The further processing of these parts and the assembly operations that occur in China do not substantially transform them into new or different articles. As such, we hold the opinion that the country of origin for the miter shears 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