The country of origin of a combination wrench, a combination wrench set, a flare nut wrench, a flare nut wrench set and an adjustable wrench

N355031 November 10, 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 combination wrench, a combination wrench set, a flare nut wrench, a flare nut wrench set and an adjustable wrench 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. The items under consideration are identified as a combination wrench, a combination wrench set, a flare nut wrench, a flare nut wrench set and an adjustable wrench. Pictures of the items in different stages of manufacture were included with your submission, along with narratives of the manufacturing processes. The combination wrench incorporates an open-ended wrench on one side with a closed ring-shaped box end wrench on the other side. The combination wrench set will include various sizes of combination wrenches packaged in a plastic holder. Flare nut wrenches are similar to combination wrenches except that both ends are open and slightly offset. The flare nut wrench set will include various sizes of flare nut wrenches packaged in a plastic holder. The adjustable wrench consists of a handle that incorporates the fixed side of the adjustable jaws and the moveable side, which can be adjusted by turning a worm gear. You have stated that the manufacturing process for the combination wrench, combination wrench set, flare nut wrench, and flare nut wrench set is the same. It begins in Vietnam, where the entire body of each wrench is cold forged from steel bar imported from China. The forging produces blanks that closely approximate the final shape of the wrenches, although the working ends of the wrenches are still filled with metal. The blanks are shipped to China for finishing operations that include grinding, machining the ends, heat treatment, vibration polishing, plating, and packaging. The manufacturing process for the adjustable wrench begins in Vietnam, where the handle is produced. A vertical press is used to hot forge a heated steel billet to the approximate shape of the handle, including the fixed side of the jaw. The adjustable side of the jaw is similarly hot forged in Vietnam. The two pieces are then sent to China where they are machined on hydraulic flattening machines and milling machines to ensure all critical dimensions are accurate. The pieces are then polished, plated and assembled to connect the moveable jaw and worm gear to the handle. Finally, the finished adjustable wrench is 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 combination wrench, flare nut wrench, adjustable wrench, and two wrench sets, it is our view that raw steel is substantially transformed in Vietnam into a recognizable tool blank of each individual wrench. 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 direct use, the tool blanks that arrive in China have a pre-determined use and are in a dedicated physical form of wrenches. Therefore, it is our determination that the country of origin of the combination wrench, combination wrench set, flare nut wrench, flare nut wrench set, and adjustable wrench 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division