The country of origin of a multi tool

N354220 October 15, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a multi tool Dear Ms. Jin: In your letter dated September 26, 2025, you requested a country of origin ruling on a multi tool. Descriptive literature was provided for our review. The device under consideration is a 14-in-1 outdoor and wilderness survival tool, which is a pocket wallet sized multi-tool that mainly contains two parts, a SUS420 stainless steel card and a piece of polyester rope. The device has 14 functions including a survival saw, rope, 2 blade edges, screwdriver, navigation device, nail pry, ruler, bottle opener, can opener, wrench, and more. It can also be fashioned into a rugged hatchet for chopping and a tool for digging. The cord could be used to tie together a shelter, hang food out of reach of animals, as a first aid tourniquet, or makeshift bow string. The device measures 3.35 inches by 2.09 inches by 0.07 inches and weighs 1.52 oz. In Vietnam, the stainless steel plate sourced from various countries, is stamped into the final size and shape of the multi-use tool, then the blanks of the multi tool card are sent to China for further barrel finishing, sharpening, black oxide finishing, laser etching of the logo and measurements, and finally assembled together with the polyester cord from China into a multi-use tool. When determining the country of origin, 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 origin of the survival tool, it is our view that while the tool has the general shape and size of the finished article, it lacks usability of many of the tools. The hex wrench, nail pry, and bottle opener would be usable upon leaving Vietnam. However, the screw drivers, can opener, survival saw, and knife blade would all require additional processing in order to properly operate. The ruler, survival rope, and morse code identifiers are all completely lacking when leaving Vietnam. Additionally, several abilities are listed in your letter that coincide with the functionality of the survival tool. For example, you mention the ability to use the survival tool as a rugged hatchet for chopping, the cord can be used to tie a shelter together, hang food out of the reach of animals, as a first aid tourniquet, or as a makeshift bow string. Each of those functions are not possible until the processing is complete in China. Therefore, in our opinion, the country of origin of the survival tool is China, as that is where it is transformed into a new article with a different name, character and use. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division