The country of origin of a corner clamp

N355065 October 28, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a corner clamp Dear Ms. Jin: In your letter dated October 21, 2025, you requested a country of origin determination for the purposes of Section 301 and IEEPA duties. Pictures of the merchandise in different stages of manufacture were included with your submission, along with a narrative of the manufacturing processes. The item under consideration is a corner clamp, which is a tool designed to hold two workpieces securely at a precise 90-degree angle. The body of the clamp is constructed from aluminum and includes two fixed jaws juxtaposed at a 90-degree angle. Two zinc alloy pressure plates are assembled with the body via adjustable screws with T-handles. The manufacturing process for the corner clamp begins in Vietnam, where aluminum is cast and molded into the final shape and size of the clamp’s body. The body is then sent to China where it is polished and assembled with two Chinese-origin plates, adjustable screws, T-handles and washers. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional 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 corner clamp, we find that a substantial transformation occurs in Vietnam where aluminum is cast and molded into the body of the corner clamp. It is the body that provides the major structural and visual component of the finished clamp. When the body is exported from Vietnam, it is in the final shape and likeness of the finished corner clamp and has a predetermined use. While the component assembly that occurs in China is necessary for the production of the finished corner clamp, it is not extensive enough to alter the fundamental character of the body of the clamp. Therefore, it is the opinion of this office that the country of origin of the finished corner clamp 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