The country of origin of a ratcheting wrench, a ratcheting wrench set and a ratchet handle

N355030 October 30, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn, LLP 303 E. Wacker Drive, Ste. 305 Chicago, IL 60601 RE: The country of origin of a ratcheting wrench, a ratcheting wrench set and a ratchet handle Dear Mr. Friedman: In your letter dated October 20, 2025, on behalf of your client, Apex Tool Group, you requested a country of origin determination for purposes of Section 301 and IEEPA duties. Pictures of the items in different stages of manufacture were included with your submission, along with narratives of the manufacturing processes. The items under consideration are identified as a ratcheting wrench, a ratcheting wrench set and a ratchet handle. The ratcheting wrench has an open box wrench at one end and a circular closed wrench with an integrated ratchet mechanism at the other end. The ratcheting wrench set includes six of these wrenches in various sizes. The ratchet handle is a hand tool composed of a long handle/neck with a circular ratcheting head that allows the user to attach a variety of sockets so that it can turn screws, bolts, and nuts. The manufacturing process for the ratcheting wrench begins in Vietnam, where the body of the wrench is hot forged from steel bar imported from China. The hot forging produces a blank that closely approximates the final shape of the wrench with both ends still filled with metal. The blank is then shipped to China for finishing operations that include grinding, machining out both ends and assembling the ratcheting mechanism into the circular head. Finally the ratcheting wrench is heat-treated, vibration polished, plated, and packaged. The manufacturing process for the ratcheting wrench set is the same as the production for the ratcheting wrench. The forged blanks are produced by the same supplier in Vietnam that produces the ratcheting wrench. The finishing operations are done in China, and the wrenches are packaged in a plastic carrier. The manufacturing process of the ratchet handle begins in Vietnam where steel is cold forged into the final shape and size of the ratchet handle and its circular head. After forging, the ratchet handle is sent to China where it is machined, heat-treated, polished, and plated. Finally, components of unknown origin are assembled and installed into the ratchet handle’s circular head to complete the ratcheting mechanism. 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 ratcheting wrench and ratcheting wrench set, it is our view that steel bar is substantially transformed in Vietnam into recognizable tool blanks. Based on the submitted information and pictures of the wrenches, it is our opinion that no article emerges from the finishing operations in China with a new name, character, or use different from that prior to processing. Although not ready for immediate use, the tool blanks that arrive in China have a pre-determined use and are in a dedicated physical form of ratcheting wrenches. Therefore, it is our determination that the country of origin of the ratcheting wrench and ratcheting wrench set is Vietnam. In regard to the ratchet handle, the forged handle manufactured in Vietnam is exported to China with a pre-determined end use as a type of ratchet handle. Functionally, the forged handle and its circular head enable a user to grip and manually apply the force required to tighten fasteners. In totality, the processing and assembly operations in China do not substantially transform the forging from Vietnam. No article emerges from the operations in China with a new name, character, or use. Accordingly, the country of origin of the ratchet handle will 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 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division