The country of origin of a spark plug socket

N352167 August 14, 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 a spark plug socket Dear Ms. Jin: In your letter dated August 8, 2025, you requested a country of origin determination for the 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 a spark plug socket, which is used for removing and installing spark plugs in engines. The spark plug is made of chrome alloy steel and has a magnetic hexagonal head. A swivel extension bar is permanently attached to one end of the spark plug, which allows for greater maneuverability when accessing spark plugs in tight or deep engine compartments. The extension bar has a 3/8 inch square driver that enables it to attach to a ratchet handle or other drive tools. You propose two manufacturing scenarios. Scenario one: The manufacturing process begins in Vietnam, where raw steel coil is cold forged into the size and shape of the spark plug socket. This includes forming the hexagonal head and the opening for the extension bar, before it is sent to China. In China, raw steel coil is cold forged into the size and shape of the extension bar. The exteriors of the spark plug socket and extension bar are then precision shaped and chamfered. A hole is drilled in the spark plug socket for assembly purposes, and a magnetic ring is inserted into the hexagonal head. Finally, the spark plug socket and extension bar are heat treated, surface treated and manually assembled together with small Chinese-origin parts. Scenario two: This scenario is the same as scenario 1, except the extension bar is cold forged in Vietnam and then sent to China for processing and assembly. 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 finished spark plug socket with the attached extension bar, it is our view that in both of your manufacturing scenarios raw steel coil is substantially transformed in Vietnam into a fully formed spark plug socket. This includes forming the hexagonal head. It is the spark plug socket that contributes to the main functionality and holds the essential identity of the finished tool. While the attachment of the extension bar provides for greater maneuverability when accessing spark plugs in tight or deep engine compartments, it is the spark plug socket that removes the spark plug from the engine. The further processing and assembly with the extension bar in China do not substantially transform the spark plug socket into a new or different article. As such, we hold the opinion that for both of your manufacturing scenarios the country of origin of the spark plug socket with the attached extension bar 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