The tariff classification and country of origin of pliers

N355091 October 30, 2025 CLA-2-82:OT:RR:NC:N1:118 CATEGORY: Classification; Origin TARIFF NO.: 8203.20.4000; 8203.20.6030; 9903.02.69 Johnathan Cho Johnathan Cho DBA A&A Customs Service 12140 Artesia Blvd. Artesia, CA 90701 RE: The tariff classification and country of origin of pliers Dear Mr. Cho: In your letter dated October 21, 2025, you requested a classification and country of origin ruling on behalf of your client, World Honor Vietnam Co., Ltd., for five pairs of pliers. The pliers are primarily made of steel and are identified as diagonal pliers, long nose pliers, long reach pliers, slip joint pliers and tongue-and-groove pliers. You provided photographs and descriptions of the manufacturing processes for each tool. The features and characteristics of the tools are listed below. Diagonal pliers, item DAP001-2, are used for cutting wire. They are made of two pieces of steel, with each piece providing half of the handle and half of the working end. The plane defined by the cutting edges of the jaws intersects the joint rivet at an angle or “on a diagonal.” The jaw edges are ground to a symmetrical “V” shape, and they cut by indenting and wedging the wire apart. Long nose pliers, item LNP001-2, are gripping, pinching, and holding pliers. They incorporate long thin jaws with a small cutting edge near the pliers’ joint. They are made of two pieces of steel, with each piece providing half of the handle and half of the working end. When joined together, the joint provides a fulcrum that transfers and increases the force applied to the handles by the user to the working end. Long reach pliers, item LRP001-4, are similar to long nose pliers except they have longer handles and jaws. They are used to grip and manipulate objects in deep, narrow or confined places. Slip joint pliers, item SJP001-2, are designed with a pivot joint, which allows the user to adjust the jaws to two different positions. Tongue-and-groove pliers, item TGP001-5, are characterized by a grooved joint, which allows the user to adjust the jaws to multiple positions at a variety of widths. They also feature handles that are at an angle to the jaws. Classification The applicable subheading for the tongue-and-groove pliers (item TGP001-5) and slip joint pliers (item SJP001-2) will be 8203.20.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof: pliers (including cutting pliers), pincers, tweezers and similar tools, and parts thereof: other: slip joint pliers. The general rate of duty will be 12 percent ad valorem. The applicable subheading for the diagonal pliers (item DAP001-2), long nose pliers (LNP001-2), and long reach pliers (item LRP001-4) will be 8203.20.6030, HTSUS, which provides for files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof: pliers (including cutting pliers), pincers, tweezers and similar tools, and parts thereof: other: other (except parts): pliers. The general rate of duty will be 12¢/doz. + 5.5 percent ad valorem. Country of Origin You submitted a narrative of the manufacturing process, along with production process flow charts and bills of materials for each tool. For all of the pliers, raw steel is sourced from China and sent to Vietnam where it is wholly manufactured into the finished tools. The manufacturing process starts with cutting and forging the steel into the overall shape of each tool. Further processing in Vietnam includes heat-treatment, drilling holes, electroplating, dip molding plastic grip handles, laser marking, testing, assembly and packaging. 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 country of origin of the five pairs of pliers under consideration, it is our view that raw steel is substantially transformed in Vietnam into finished tools. As demonstrated in your production flow charts, all manufacturing, assembly and finishing operations occur in Vietnam. It is therefore the opinion of our office that the country of origin of the diagonal pliers, long nose pliers, long reach pliers, slip joint pliers and tongue-and-groove pliers is Vietnam. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Vietnam will be subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheadings 8203.20.4000 and 8203.20.6030, HTSUS, listed above. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. 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