The tariff classification and country of origin of wrenches

N355092 October 28, 2025 CLA-2-82:OT:RR:NC:N1:118 CATEGORY: Classification; Origin TARIFF NO.: 8204.12.0000; 8204.11.0030; 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 wrenches 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 types of wrenches. Each wrench is primarily made of steel and is used to tighten and loosen various sizes of nuts and bolts. They are identified as follows: adjustable wrench, locking adjustable wrench, flare nut wrench, flex flare nut wrench, ratcheting combination wrench. You provided photographs and descriptions of the manufacturing processes for each tool. The features and characteristics of the tools are listed below. The adjustable wrench, item ADW001-5, incorporates a fixed jaw and moveable jaw that is adjusted by a thumb screw. The locking adjustable wrench, item LAW001-1, is similar to an adjustable wrench except it also includes a locking mechanism that locks the jaws in place. The flare nut wrench, item FNW001-7, incorporates two U-shaped openings at each end of its body. The flex flare nut wrench, item FFN001-2, is similar to a flare nut wrench except each end is flexible, which allows the wrench to be positioned at different angles to reach difficult-to-access nuts. The ratcheting combination wrench, item RCW001-16, combines a ratcheting box-end on one side of one side of its body with an open-end on the other. This allows for continuous rotation of fasteners in tight spaces. Classification The applicable subheading for the adjustable wrench (item ADW001-5) and the locking adjustable wrench (item LAW001-1) will be 8204.12.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives or extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: adjustable, and parts thereof. The general rate of duty will be 9 percent ad valorem. The applicable subheading for the flare nut wrench (item FNW001-7), flex flare nut wrench (item FFN001-2), and ratcheting combination wrench (item RCW001-16) will be 8204.11.0030, HTSUS, which provides for hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives or extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: nonadjustable, and parts thereof: open-end, box and combination open-end and box wrenches. The rate of duty will be 9% ad valorem. Country of Origin You submitted a narrative of the manufacturing processes, along with production process flow charts and bills of materials for each tool. For all of the wrenches, raw steel is sourced from China and sent to Vietnam and 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 includes, but is not limited to, heat-treatment, electroplating, 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 wrenches 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 this office that the country of origin of the adjustable wrench, locking adjustable wrench, flare nut wrench, flex flare nut wrench, and ratcheting combination wrench 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 8204.12.0000 and 8204.11.0030, 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