The country of origin of swivel head ratchet

N352166 August 14, 2025 OT:RR:NC:N1:164 CATEGORY: Origin Fay Jin Great Star Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of swivel head ratchet Dear Ms. Jin: In your letter dated August 8, 2025, you requested a country of origin ruling on a swivel head ratchet. Product information was submitted with your request. The item under consideration is described as a swivel head ratchet used to apply a certain amount of torque to ensure fasteners are tightened to specification. The swivel head ratchet primarily consists of a handle and a swivel head of chrome vanadium alloy steel. During use, the swivel head provides a 270-degree range of motion around a horizontal pivot connection with the handle. This swiveling feature allows a user to access hard to reach areas while maintaining functionality. The integral ratchet mechanism features a forward and reverse switch which can be toggled by a user to limit tightening or loosening to one direction. In addition, the swivel head contains a locking mechanism to prevent a socket from detaching during use. A release button on the rear side of the swivel head allows a user to unlock the socket connection for removal. The handle features a grip of polypropylene plus thermoplastic rubber. You state that the ratchet drive is suitable for use with 1/4 inch sockets. The swivel head ratchet measures 5.875 inches in length, 1.2 inches in width, and 1.1 inches in depth. The production process begins in Vietnam where raw steel coils are drop-forged into the sizes and shapes of the ratchet handles and swivel heads. Then, the two forged components are shipped from Vietnam to China where they undergo machining processes such as milling and grinding operations to achieve precise dimensions and surface quality. Following that, the components undergo heat treatment consisting of quenching and tempering. At that point, the components are electroplated to enhance the surface’s corrosion resistance and aesthetic quality. Finally, the ratchet handle and swivel head are manually assembled with several Chinese-origin components, including the grip, drive tang, turntable, directional knob, pawl, springs, retaining rings, release button, and steel ball. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional 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 the instant scenario, the forged handles and swivel heads manufactured in Vietnam are exported to China with a pre-determined end use as a type of ratchet handle. Although they are separate components, after assembly, they are permanently attached to make one cohesive ratchet handle. Functionally, the handle and swivel head enable a user to grip and manually apply the force required to tighten fasteners while allowing for freedom of movement and directional change. Furthermore, the totality of processing and assembly operations in China does not result in a substantial transformation of the forged ratchet handle components from Vietnam. No articles emerge from the operations in China with a new name, character, or use. Accordingly, the country of origin of swivel head ratchet will 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division