The country of origin of a replacement lineman knife blade from Vietnam.

N353997 October 15, 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 a replacement lineman knife blade from Vietnam. Dear Mr. Liu: In your letter dated August 22, 2025, you requested a country of origin ruling on behalf of your client, Kunjek Industry. Images were provided in lieu of a sample. The product under consideration is described as a lineman knife replacement blade, item number LB-QC3PK-1P. It is designed for use with lineman knives, which are knives that feature specialized blades commonly used by electrical linemen, telecommunications technicians, and construction workers. This blade is primarily used for stripping cable insulation and cutting rope, zip ties, and other materials at job sites. Per your submission, it will consist solely of the blade body without a handle or other components. This blade will undergo the following production and processing steps. In Vietnam, the blank will be stamped to shape. It will then be shipped to China where it will be heat treated, vibratory finished, double hollow ground, and the edge sharpened. Finally, the blade will be packaged and exported to the United States. 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 this replacement lineman knife blade, and we agree with the opinion that the blade blank holds the essential identity of the finished knife blade and the further processing in China would not substantially transform it. As such, the country of origin for the lineman knife replacement blade, item number LB-QC3PK-1P, would 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division