The country of origin of long nose pliers, diagonal pliers, linesman pliers, and groove joint pliers

N352986 September 18, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Anne Brandon Yormick Law LLC 5900 Landerbrook Drive, Suite 205 Cleveland, OH 44124 RE: The country of origin of long nose pliers, diagonal pliers, linesman pliers, and groove joint pliers Dear Ms. Brandon: In your letter dated August 27, 2025, on behalf of your client, The Davidson Works Co., Ltd., you requested a country of origin determination ruling for four different types of pliers for purposes of Section 301 and IEEPA duties. The first type are long nose pliers that will be imported in 6" and 8" sizes. The second are diagonal cutting pliers imported in 6", 7.5" and 8" sizes. The third are linesman pliers imported in 8", 9", 9.5" and 9.75" sizes. The fourth are groove joint pliers imported in 8", 10", 12", 16" or 20" sizes. Long nose pliers feature long, narrow jaws that taper to a point, making them ideal for precision tasks such as electrical work. Diagonal cutting pliers have angled jaws for clean, accurate wire cutting. Lineman pliers are built for gripping, twisting, cutting, and crimping wires, commonly used in electrical and construction applications. Groove joint pliers are adjustable and designed to grip and turn objects of different sizes. All of the pliers will be manufactured from either chrome vanadium steel or standard steel. You have stated that the manufacturing process for each style of pliers is substantially the same, apart from component costs. In each case, the manufacturing process begins in Vietnam, where raw steel is forged into rough castings of the two halves of the pliers (i.e., the pieces incorporating the handles and jaws). These pieces are then bent, shaped and trimmed of excess material. Further in Vietnam, they are heat treated, polished and shaped to ensure proper alignment. Pivot holes are punched into each piece, and they are aligned using a locating pin and temporarily fastened. The jaws of the pliers are then milled to precision. The pliers are then sent to China, where they are heat treated to increase hardness and permanently assembled with a rolling rivet. They are surface finished, cleaned and a corrosion resistant oil is applied. Finally, the pliers are laser marked, PVC plastic grips are applied to the handles, the jaws are dipped in rust-preventative oil, and they 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). Regarding the country of origin of the four styles of pliers, it is our view that raw steel is substantially transformed in Vietnam into the two halves of the pliers (i.e., the pieces incorporating the handles and jaws), where they are bent and shaped into their final form, and the jaws of the pliers are milled to precision. These articles provide the principal characteristics and main functionality of the finished tools, are dedicated for use as such, and cannot be used for any other purpose. The character of these articles remains unchanged after the manufacturing processes and assemblies that occur in China. Therefore, it is the opinion of our office that the country of origin of the long nose pliers, diagonal pliers, linesman pliers, and groove joint pliers 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) Denise Faingar Acting Director National Commodity Specialist Division