The country of origin of scissors from Vietnam.

N352762 September 12, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Vincent Liu Olympia Tools International, Inc. 929 North Grand Avenue Covina, CA 91724 RE: The country of origin of scissors from Vietnam. Dear Mr. Liu: In your letter dated August 22, 2025, you requested a country of origin ruling. Images were provided in lieu of samples. The products under consideration are three different types of scissors and are described in your submission as heavy duty, non-slip soft-grip, and standard. They are all made with stainless steel cutting blades, a tension screw, and plastic comfort grips. We note that you state that this request features identical products and production scenarios as New York Ruling Letter (“NY”) N347613, dated May 6, 2025. Heavy Duty Scissors Production: In Vietnam the raw stainless steel is stamped into two blade blanks. You state that at this stage, the blanks already exhibit their final shape, size, and form. In China the finger and assembly holes are punched, the blades are heat treated and sharpened, and the injection molded handles are attached. The scissors will then be packaged for retail sale. Non-slip Soft-Grip Scissors Production: In Vietnam the raw stainless steel is stamped into blade blanks. You state that at this stage, the blanks already exhibit their final shape, size, and form. In China the screw hole is punched, the blade is heat treated and sharpened, and the injection molded comfort grips are pushed onto the scissors. They will then be packaged for retail sale. Standard Scissors Production: In Vietnam the raw stainless steel is stamped into blade blanks. You state that at this stage, the blanks already exhibit their final shape, size, and form. In China the screw and finger holes are punched, the blades are heat treated and sharpened, and one plastic comfort grip handle is attached. The scissors will then be packaged for retail sale. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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 order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. This office reviewed the submitted production process of these three types of scissors. As you state that this request is materially the same as NY N347613, we maintain the opinion that the blade blanks hold the essential identity of these finished scissors and the further processing in China would not substantially transform them. As such, the country of origin for these three types of scissors would also 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 (“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 CBP Regulations (19 CFR 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division