The tariff classification and country of origin of long nose pliers

N352414 August 21, 2025 CLA-2-82:OT:RR:NC:N1:118 CATEGORY: Classification; Origin TARIFF NO.: 8203.20.6030; 9903.02.69 Christopher Li Test Rite Products Corporation 1900 S Burgundy Pl. Ontario, CA 91761 RE: The tariff classification and country of origin of long nose pliers Dear Mr. Li: In your letter dated August 14, 2025, you requested a tariff classification and country of origin determination ruling for a 6" long nose pliers, item number GM8701. You provided photographs and descriptions of each stage of the manufacturing process for the pliers. A pair of long nose pliers (also known as needle-nose pliers) is a hand tool generally used to grip, pinch, bend or cut wire. They incorporate long thin jaws with a small cutting edge near the pliers’ joint. The pliers are made of two pieces of steel, with each piece providing half of the handles and half of the jaws. When joined together, the joint provides a fulcrum that transfers and increases the force applied to the handles by the user to the jaws. Classification The applicable subheading for the 6" long nose pliers, item number GM8701, will be 8203.20.6030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof: Pliers (including cutting pliers), pincers, tweezers and similar tools, and parts thereof: Other: Other (except parts). Pliers. The general rate of duty will be 12¢/doz. + 5.5 percent ad valorem. Country of Origin The manufacturing process for the long nose pliers begins in Vietnam, where Chinese-origin steel rods are drop-forged into the left and right pieces of the pliers (i.e., the pieces incorporating the handles and jaws). These two halves of the pliers are then sent to China, where they are precision machine-shaped and two holes are drilled into each piece so that they can be joined together. Teeth are cut into the jaws, and the pieces undergo heat-treatment and polishing. Finally, the two halves are assembled with a rivet, laser marked with a logo, plastic grips are slipped over the handles, and the finished pliers are packaged for retail sale. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding the long nose pliers, it is our view that a substantial a transformation occurs in Vietnam. It is here that steel rods are drop-forged into the final size and shape of the left and right jaws and handles of the tool. These components contribute to the main functionality of the finished tool, which is to grip, pinch, bend or cut wire. Based on the provided descriptions and pictures of the additional processing and assembly operations performed in China, these components are not substantially changed so as to transform them into new articles with a different name, character, or use. It is therefore the opinion of this office that the country of origin of the 6" long nose pliers, item number GM8701, is Vietnam. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Vietnam will be subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading 8203.20.6030, HTSUS, listed above. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. 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